Defendant’s first minute-long patdown was unreasonable, but produced nothing. There was no separate reasonable suspicion for the second one. State v. Barcus, 2022-Ohio-2491, 2022 Ohio App. LEXIS 2355 (5th Dist. July 20, 2022).
Police went to defendant’s house on a welfare check on his grandmother who took him in. Inside, the officer saw dried blood on the floor so police got a search warrant. Defendant’s cogent questions and response to the search warrant helped the state to show he wasn’t insane. State v. Stowe, 2022 Iowa App. LEXIS 560 (July 20, 2022).*
“Because defendant failed to present his relatively novel constitutional argument [about the search] below, we cannot conclude that the purposes of preservation—including ensuring that the trial court and the opposing party had an opportunity to address the issues raised—have been served.” State v. Moore, 321 Or. App. 28, 2022 Ore. App. LEXIS 1058 (July 19, 2022)* (unpublished).