D.P.R.: Indictment for possession of switches to convert handguns to machine guns justified vehicle search when defendant was stopped

Defendant was indicted for possession of conversion devices to make handguns machine guns. That justified search of his car when he was stopped. United States v. Berríos-Aquino, 2024 U.S. Dist. LEXIS 66657 (D.P.R. Apr. 4, 2024).

The DEA subpoena for patient records was properly limited in scope to only patients receiving controlled substances for a reasonable period of time. It was not unreasonably burdensome: “Like the subpoena seeking forty-seven patient files in Becker, the subpoena here is not unreasonably burdensome: it seeks all controlled-substance-related records for forty-one of Wilson’s patients, all controlled-substance prescriptions and the identities of patients who received those prescriptions for the five-year period, and beyond that, the total number of patients he saw during that time.” As the holder of the records, he had standing to challenge the subpoena. United States v. Wilson, 2024 U.S. App. LEXIS 9017 (10th Cir. Apr. 15, 2024).

The sound of someone moving inside was sufficient for a protective sweep. United States v. Wheeler, 2024 U.S. Dist. LEXIS 67631 (W.D. Pa. Apr. 15, 2024).*

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