The officer bumped defendant on a bike. It was potentially a seizure, but “Under Hodari D. and Torres, the seizure thus ended when Daniels got up and began running down the driveway.” United States v. Daniels, 2022 U.S. Dist. LEXIS 88072 (N.D.Cal. May 16, 2022).
It is harder to show staleness during an ongoing drug dealing offense. United States v. Fort, 2022 U.S. Dist. LEXIS 88117 (E.D.N.C. Mar. 29, 2022).*
During a traffic stop with the occupants out of the car, officers had reasonable suspicion for a protective sweep and found a gun. The tougher question of defendant’s standing as a passenger doesn’t have to be decided. United States v. Rodriguez, 2022 U.S. App. LEXIS 13021 (5th Cir. May 13, 2022).*