“‘[A] one-frisk-only rule would create a privacy-adverse Fourth Amendment incentive’ for officers to perform ‘the most intrusive frisk possible the first time around, knowing that no more would be allowed.’” Here, there was reasonable suspicion for both frisks. United States v. Smith, 2022 U.S. App. LEXIS 10969 (7th Cir. Apr. 22, 2022).
Defendant was arrested in a restaurant with his cell phone inches from his hand. The officers took the phone and this was reasonable incident to the arrest. Search of the phone followed with a warrant. United States v. Hooper, 2022 U.S. App. LEXIS 10915 (4th Cir. Apr. 21, 2022).*
Without the dog sniff, this was a close case, but there was at least reasonable suspicion for continuing the stop for the dog sniff. United States v. Young, 2022 U.S. Dist. LEXIS 72985 (E.D.Va. Apr. 20, 2022).*