There was reasonable suspicion for defendant’s intensive exit border search of his electronic devices. “The officers and agents had background information, much of it corroborated, that provided a basis for assessing Xiang’s actions in May and June 2017. Their experience and training in international economic espionage and theft of trade secrets gave them reasonable suspicion for an extended border search that included a forensic search of electronic devices.” United States v. Haitao Xiang, 2023 U.S. App. LEXIS 11027 (8th Cir. May 5, 2023).
Having convicted defendant, the government doesn’t show need to keep his four cell phones, and they should be returned. United States v. Robinson, 2023 U.S. Dist. LEXIS 78365 (D. Alaska May 4, 2023).
Officers driving by saw a group of men drinking on street in violation of state and city law. They got out of their cars and approached. Defendant visibly had a clip holster in his belt. The frisk for a weapon was reasonable. People v. Hicks, 2023 Mich. App. LEXIS 3184 (May 4, 2023) (unpublished).*
Defendant’s traffic stop led to observation that he was likely DUI, and the FST was reasonable. State v. Johnson, 2023 Fla. App. LEXIS 3063 (Fla. 5th DCA May 5, 2023).*