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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State v. Sizer

STATE OF MARYLAND v. JAMAL RASHEED SIZER
Court of Special Appeals, Moylan, Nov. 29, 2016,
Terry Stop – For Terry purposes, a “high-crime area” need not be as violent as Wardlow‘s south Chicago.

Affirmed on other grounds by COA

(Concur – Graeff- Agrees that stop was valid, evidence shouldn’t be excluded even if stop invalid, but disagrees and thinks the “but-for”/”attenuation” analysis is proper)
(Judge Moylan writes individually to explain the difference between Attenuation, Independent Source, and Inevitable Discovery)
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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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Bellard v. State

DARRELL BELLARD v. STATE OF MARYLAND
Court of Special Appeals, Nazarian, August 31, 2016,
Murder – Sentencing – Statutory remnants of the repeal of the death penalty did not create a new sentencing procedure that allowed for election of sentencing by jury in 1st Degree Murder trials

affirmed by CoA
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