United States v. Moreno, No. 19-3483 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized as a result of a protective frisk. The court concluded that the officer performed a lawful, protective search based on reasonable articulable suspicion that defendant may have been armed. In this case, the officer's targeted, protective search was sufficiently limited to dispel his concerns that the bulge under defendant's clothing may have been a weapon.
Court Description: [Erickson, Author, with Benton and Grasz, Circuit Judges] Criminal case - Criminal law. The police performed a lawful, protective search based on a reasonable articulable suspicion that defendant may have been armed, and the district court did not err in denying her motion to suppress the fruits of the protective frisk. Judge Grasz, concurring.
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