Appellant resisted an illegal patdown and was Tased and charged with obstruction and resisting. A new offense is an intervening circumstance under Brown, and it doesn’t matter whether it is “serious” or not. Massey v. State, 2023 Tex. Crim. App. LEXIS 278 (Apr. 26, 2023).
There was justification for a protective weapons search under the driver’s seat that the driver could get access to if he got back into the car. United States v. Erving, 2023 U.S. Dist. LEXIS 70832 (C.D. Ill. Apr. 24, 2023).*
Lack of additional support for the CI’s credibility wasn’t important when there was additional other information that showed probable cause. United States v. Foster, 2023 U.S. Dist. LEXIS 70890 (N.D. Ala. Apr. 24, 2023).*
Crossing the white line justified the stop, and the smell of marijuana came from the car. United States v. Crawford, 2023 U.S. Dist. LEXIS 71226 (N.D.W. Va. Apr. 24, 2023).*