NY1: Furtive movements by occupants of vehicle justified search of car for weapons

Furtive movements under the seat at the time of stop with one occupant opening and closing the glove compartment and another feigning sleep justified a protective sweep of the car. People v Newman, 2012 NY Slip Op 2816, 96 A.D.3d 34, 942 N.Y.S.2d 93 (1st Dept. 2012).*

The trial court held that the defendant lacked standing to contest a search, and defendant did not show that defense counsel was ineffective for not getting to the merits of the search. State v. Jackson, 2012 N.C. App. LEXIS 510 (April 17, 2012).*

A wiretap in New York provided probable cause defendant would be picking up drugs in Tennessee. Defendant had a suspended DL, and the owner also consented to the search. United States v. Prater, 2012 U.S. Dist. LEXIS 53739 (E.D. Tenn. February 17, 2012).*