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“To the extent there exists any inconsistency between Robinson and Ingle, any uncertainty by commentators, or any “confusion among courts” … , stopping a vehicle for a traffic infraction requires probable cause; stopping a vehicle for suspicion of criminal activity requires less: “reasonable suspicion that the driver or occupants of the vehicle have committed, are committing, or are about to commit a crime”.”
Barry Kamins, New York Search & Seizure 2022 Edition

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