IVAN POTTS v. STATE OF MARYLAND
Court of Special Appeals, Wright, Dec. 28, 2016,
Merger – Where a prohibited person is convicted of possession of a regulated firearm under PS 5-133(c)(1) and possession of ammunition under PS 5-133.1, the sentences do not merge.
UNITED STATES OF AMERICA v. SHAQUILLE MONTEL ROBINSON
US Court of Appeals for the 4th Circuit, Harris, Filed Feb. 23, 2016,
VACATED, EN BANC – opinion by Niemeyer
Seizure – “Because West Virginia authorizes the public carrying of weapons, reasonable suspicion that [an individual] was armed did not by itself justify a Terry frisk”
(Dissent by Niemeyer – 1) The standard is armed and THUS dangerous, 2) the possibility of a valid firearm license did not acceptably minimize the danger to officers, and 3) RAS is not the negation of all possible innocent conduct)
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