E.D.La.: Protective sweep before warrant was sought was violation of the Fourth Amendment, but the SW was saved by independent PC of informant hearsay

A protective sweep of premises in anticipation of a search warrant being sought was unreasonable where there were no facts supporting even an inference that there was another person inside after officers surveilled the premises watching its comings and goings. Observations in the protective sweep were included in the search warrant. The government, however, satisfied its burden of showing probable cause in the remaining information in the affidavit on informant hearsay. United States v. Glover, 2012 U.S. Dist. LEXIS 115461 (E.D. La. August 16, 2012).*

Walking in the street in a high crime area where there are sidewalks is a traffic offense in Missouri, and a search incident was permitted. This is the same as United States v. Pratt, 355 F.3d 1119 (8th Cir. 2004). United States v. Moore, 2012 U.S. Dist. LEXIS 114645 (W.D. Mo. July 24, 2012).*

Officers were investigating a drug trafficking organization and they had at least reasonable suspicion to stop defendant when he was leaving a suspected warehouse of the drugs, but defendant committed a traffic offense. He was removed to the back of a police car, and a dog alerted within 1½ minutes. The stop was reasonable. United States v. Braden, 2012 U.S. Dist. LEXIS 115275 (W.D. Tenn. August 16, 2012).*