California, United States of America
The following excerpt is from People v. Jose O., F061531 (Cal. App. 2011):
In addition, we note two other factors that support our conclusion. First, the vehicle stop in the instant case occurred at 8:41 p.m. (People v. Satchell (1978) 81 Cal.App.3d 347, 354 [upholding patsearch for weapons based on, in part, the fact that "[t]he area was dark and preparatory movements by defendant and his [companion] might easily go unnoticed"].) Second, the two officers here were confronted with appellant, who was 16 years old at the time, and two adults. Whether the police do or do not have a numerical advantage over the suspect(s) is also a relevant factor in determining the
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