MI: Merely passing money to a man in car who counted it is not RS

Merely passing money to a man in car who counted it is not reasonable suspicion. People v. Soulliere, 2022 Mich. LEXIS 798 (Apr. 22, 2022).

Defendant was stopped for an alleged unsafe lane change and expired Pennsylvania tags. There was a factual basis for the former as shown by the dashcam video, and other appellate courts in the state have upheld stops on similar facts. At the time of the stop, an executive order in Ohio extended car tag renewals because of Covid. The officer had no reason to know whether Pennsylvania did, but it was expired on its face. State v. Triplett, 2022-Ohio-1371, 2022 Ohio App. LEXIS 1259 (5th Dist. Apr. 22, 2022).*

A rifle in the back seat seen in plain view in an unattended vehicle was a potential danger to the public, so officers could retrieve it for public safety reasons. United States v. Shine, 2022 U.S. Dist. LEXIS 74447 (W.D.N.C. Apr. 25, 2022). [Classic community caretaking search]

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