C.D.Ill.: Officer called it a patdown, but it was valid as a SI

The officer said he was going to patdown the defendant for a weapon after defendant said he had a gun on him which was a violation of Illinois law. It was valid as a search incident, not a patdown. United States v. Lyons, 856 F. Supp. 2d 946 (C.D. Ill. 2012),* reconsideration after conviction denied 2012 U.S. Dist. LEXIS 61379 (C.D. Ill. May 2, 2012).*

Plaintiff’s case was not attempting to invalidate a conviction in another state case, so there was no Heck bar. Plaintiff also barely satisfies a substantive due process claim. Plaintiff’s Fourth Amendment claim doesn’t survive. Andrews v. Bureau of Codes Admin. Office, 2012 U.S. Dist. LEXIS 23835 (M.D. Pa. February 24, 2012).*

Pro se motion to suppress that states no grounds is denied. United States v. Goodrich, 2012 U.S. Dist. LEXIS 25337 (W.D. Mo. February 10, 2012).*

2255 petitioner’s claim that defense counsel was ineffective for not moving to suppress his stop is wrong; defense counsel did. United States v. Davis, 2012 U.S. Dist. LEXIS 25314 (D. Kan. February 28, 2012).*