OH1: Doing nothing unusual or criminal 5 minutes after ShotSpotter alert wasn’t RS

Officers found defendant putting his kids in his car about five minutes after a ShotSpotter alert where no one had complained of gunfire. His ultimate frisk lacked reasonable suspicion. State v. Henson, 2022-Ohio-1571, 2022 Ohio App. LEXIS 1482 (1st Dist. May 11, 2022).*

There was more than just a bare bones application for search warrant here. There was more than a “mere modicum” of evidence, and a fair amount of information to support the good faith exception applying. United States v. Burrell, 2022 U.S. Dist. LEXIS 87168 (E.D.Mich. May 14, 2022).*

During the traffic stop, the diversion to call for a drug dog was without reasonable suspicion and it extended the stop. State v. Still, 166 Idaho 351, 458 P.3d 220 (App. 2019), is overruled. State v. Karst, 2022 Ida. LEXIS 52 (May 11, 2022).*

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