W.D.N.C.: Frisk by security at a bar was purely private search

Defendant was frisked by security entering a bar, and a gun was found. They kept it for the police. This was purely a private search. United States v. Wood, 2023 U.S. Dist. LEXIS 16555 (W.D.N.C. Feb. 1, 2023).

The district court issued findings that the search of defendant’s car was justified by probable cause and the automobile exception. [It’s not even close.] United States v. Salahuddin, 2023 U.S. App. LEXIS 2401 (6th Cir. Jan. 27, 2023).*

Officers had specific information about defendant allegedly dealing drugs from a black Jaguar with its LPN. When they encountered him, there was a Terry stop and a pat down that produced a plain feel of drugs. The further search of the person was reasonable, and that led to a valid search incident of the car. United States v. Kormah, 2023 U.S. Dist. LEXIS 15860 (D. Mass. Jan. 31, 2023).*

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