California, United States of America
The following excerpt is from People v. Steffin, B256102 (Cal. App. 2015):
This case presents facts more similar to those considered by the Fifth District in People v. Dibb, supra, 37 Cal.App.4th at pp. 836-837, where the court found seizure of narcotics during a patdown lawful where it was "immediately apparent" under the totality of the circumstances that a lump the officer felt was narcotics, and by the First District in People v. Lee (1987) 194 Cal.App.3d 975, 985, in which the court found the officer's patdown using a "'grabbing or claw-type of motion'" was necessary to rule out a weapon
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