N.D.Ala.: Officer tailing GPS from bank robbery loot had exigency

“Brown first argues that counsel provided ineffective assistance by failing to raise three specific arguments in his defense: that the arresting officer violated Brown’s Fourth Amendment rights by (1) arresting Brown outside of the officer’s Birmingham jurisdiction, (2) entering a public restroom without a warrant to apprehend Brown, and (3) searching Brown’s clothing after arresting him. … Had counsel informed him of these Fourth Amendment violations, Brown contends, he would not have accepted the blind plea or would have pursued a motion to suppress.” Officers were tailing a GPS transponder from a bank robbery, and the officer had exigency to follow and enter the bathroom [And none of these suggest a constitutional violation anyway.] Brown v. United States, 2022 U.S. Dist. LEXIS 28816 (N.D.Ala. Feb. 17, 2022).*

An adult riding a bicycle near a school on a Sunday was not reasonable suspicion. “Considering the totality of the circumstances, we conclude that the State failed to clear the ‘low bar’ of reasonable suspicion and instead relied on what could be described, at most, as ‘a mere hunch’ of the deputy.” State v. Meddaugh, 2022 Wisc. App. LEXIS 142 (Feb. 17, 2022).*

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