US v. Donald Hill

UNITED STATES OF AMERICA v. DONALD T. HILL
US Court of Appeals for the Fourth Circuit, Keenan, March 30, 2017,
Second Stop – As long as at least one officer is working diligently on the original reason for the stop (and therefore the stop does not last any longer than it otherwise would), a second officer can stay with the car and conduct an unrelated investigation.

(Dissent- Davis- every minute “spent seeking to confirm [the passenger’s] identity unreasonably prolonged the traffic stop”)
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Norman v. State

JOSEPH NORMAN, JR. v. STATE OF MARYLAND
Court of Appeals, Watts, March 27, 2017,
Car Stop- Odor of Marijuana- Without more, an odor of marijuana coming from a vehicle does not allow police to frisk the occupants

Plurality
(Main opinion- Watts with Hotten)
(Join in judgment only- Greene)
(Concur- Adkins with Barbera- not reasonable to believe passenger involved in drug dealing where car smells of mj)
(Dissent- Getty with McDonald – probable cause for drugs should be RAS to frisk)
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US v. Shaquille Robinson

UNITED STATES OF AMERICA v. SHAQUILLE MONTEL ROBINSON
US Court of Appeals for the Fourth Circuit (En Banc 11-1-4), Niemeyer, Jan. 23, 2017,
Frisk – During a forced police encounter, an individual need only be “armed and thus dangerous” for an officer to conduct a frisk

(Concur- Wynn- Armed and dangerous are independent factors, but RAS the suspect has a firearm satisfies the ‘dangerous’ requirement)
(Dissent – Harris, Gregory, Motz, Davis- Armed and dangerous are independent factors)
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Santos v. State

ANTHONY SANTOS v. STATE OF MARYLAND
Court of Special Appeals, Beachley, Oct. 26, 2016,
Investigative “Terry” Stop – During car stop for a traffic violation, reasonable suspicion existed to detain the driver where he was nervous, sweating, and lied to officers about stopping and meeting with another individual. Moreover, a warrant check on the driver came back with two possible warrants, and the officers had developed probable cause before the warrant check was finalized.
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