VA: Asleep in one’s car isn’t RS

Defendant asleep in his car wasn’t reasonable suspicion. Marijuana found. Harvell v. Commonwealth, 2024 Va. App. LEXIS 142 (Mar. 19, 2024) (unpublished).*

Plaintiff’s excessive force claim under Bivens is barred by Egbert. Butler v. Trett, 2024 U.S. App. LEXIS 6469 (6th Cir. Mar. 18, 2024).

Frequent filer sued library for kicking him out, again. He’s under a screening requirement for so many frivolous cases. “Watkins’s brief encounter with law enforcement did not violate his right to be free of unreasonable searches and seizures. Although Watkins contends he was ‘detained’ by the BSO deputy, the complaint lacks any allegations that Watkins was physically restrained or that he was advised that he was not free to leave. See Chandler, 695 F.3d at 1199. And while the deputy would have been required to show reasonable suspicion that Watkins had committed or was about to commit a crime to conduct a more intrusive detention, Watkins was not subjected to a seizure within the meaning of the Fourth Amendment.” In re Watkins, 2024 U.S. App. LEXIS 6477 (11th Cir. Mar. 19, 2024).*

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