CA11: Stop on RS can’t go on indef

A stop on reasonable suspicion cannot go on indefinitely. Here, there was video of an encounter but defendant deleted it from the phone of the victim. She’d sent it to another before that, and she was trying to get it back. Also, the officer was trying to maintain the peace at the scene for safety of all, and that wasn’t a separate criminal investigation. United States v. Moore, 2023 U.S. App. LEXIS 2552 (11th Cir. Feb. 1, 2023).

The record supports the finding of reasonable suspicion to extend the stop and also consent to enter the house. Commonwealth v. Lear, 2023 PA Super 15, 2023 Pa. Super. LEXIS 39 (Feb. 1, 2023).*

Defendant was stopped for an expired tag and inspection sticker during a declared Covid hiatus that only applied to the inspection. The stop was still reasonable. United States v. Wheatley, 2023 U.S. Dist. LEXIS 15186 (S.D. W. Va. Jan. 30, 2023).*

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