All of defendant’s lies during a traffic stop added up to reasonable suspicion. “During the investigation of the initial traffic stop and Dixon’s lack of a driver’s license, Dixon lied about coming from Angie B’s, a nightclub known for high crime and drug trafficking. ‘If a false answer to a particular question would suggest a suspect’s involvement in criminal activity, then a possibly false answer can help to establish reasonable suspicion.’ … Smith also testified that Dixon (1) did not want to make eye contact, (2) was argumentative, (3) believed there was an outstanding warrant for his arrest, (4) had an arrest for a prior drug offense, (5) was driving a vehicle that was not registered to him, and (6) lied about his criminal history. See id. at 308 (‘a prior criminal record” and “[d]eception regarding one’s own criminal record [have] also been recognized as … factor[s] that can contribute to reasonable suspicion’).” Dixon v. State, 2023 Tex. App. LEXIS 2192 (Tex. App. – Texarkana Apr. 5, 2023).
In a search for drugs, it was reasonable for officers to search in places such as safes, back packs, and underneath a bed since that’s where drugs could be stored or hidden. State v. Brado, 2023-Ohio-1119 (7th Dist. Mar. 30, 2023).*