OH12: Protective sweeps didn’t require consent

The protective sweep didn’t require consent. Moreover, the argument wasn’t preserve below. State v. Mott, 2023-Ohio-2268 (12th Dist. July 3, 2023).*

Based on the totality, it was objectively reasonable to believe defendant was speeding when the officer decided to stop him. United States v. Thomas, 2023 U.S. Dist. LEXIS 114278 (D.S.D. June 2, 2023).*

There was reasonable suspicion for defendant’s stop having crossed through the Tohono O’odham Nation in an area the CBP officer knew was regularly frequented by smugglers, in the officer’s 17 years experience there. United States v. Martinez, 2023 U.S. Dist. LEXIS 114446 (D.Ariz. July 3, 2023).*

Defendant had been voluntarily in the precinct station on December 31st and he left after questioning. They got him back on January 1st and talked to him when he finally confessed. The second trip became custodial as it progressed. People v. Townsend, 2023 IL App (1st) 200911 (June 30, 2023).*

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