IL: Frisk unjustified without showing risk def was armed

Defendant’s frisk was unjustified. There was no reasonable suspicion he was armed. People v. Lozano, 2023 Ill. LEXIS 463 (Sep. 21, 2023).*

Defendant used his cell phone to arrange drug deals, and a search warrant was sought for the phone. “Though not expressly stated in the warrant application, this information is sufficient to conclude that the phone would contain the names and contact information for coconspirators, which is important investigatory information.” United States v. Parker, 2023 U.S. Dist. LEXIS 168580 (W.D.N.Y. Sep. 21, 2023).*

The affidavit for warrant showed probable cause for search of defendant’s Apartment No. 1 of a three story building. United States v. Soto-Lara, 2023 U.S. Dist. LEXIS 169109 (D. Mass. Sep. 22, 2023).*

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