After witnessing suspicious movement, and observing white powder on the vehicle dashboard where defendant had been sitting, police had probable cause to arrest defendant on drug charges and consequently were justified in conducting a search of the defendant incident to that arrest. The drug dog’s alert to defendant’s buttocks area provided probable cause for a strip search; the State provided evidence of the dog’s reliability, including the dog and its trainer’s extensive training and the procedure followed during the dog’s search at the scene. Commonwealth v. Judge, 2022 Mass. App. LEXIS 28 (Apr. 7, 2022).
A displayed syringe during a traffic stop was probable cause for a search of the car. United States v. Cheatwood, 2022 U.S. Dist. LEXIS 64021 (W.D.Va. Apr. 5, 2022).*
A police department bulletin board posting that defendant was armed and dangerous, coupled with his having a bulge in his waistband, was reasonable suspicion. United States v. Halverson-Weese, 2022 U.S. App. LEXIS 9325 (8th Cir. Apr. 7, 2022).*