N.-M.Ct.Crim.App.: Joint investigation by Belgium and Navy in NATO forces of murder of service member’s spouse by the service member was not improper

Defendant was in the Navy with NATO forces and questioned by Belgian authorities under their law for murder of his wife. This was not an improper joint investigation because both Belgium and the United States had jurisdiction over his crime. United States v. Becker, 2025 CCA LEXIS 574 (N-M Ct. Crim. App. Dec. 17, 2025) (unpublished but potentially persuasive anyway).

The traffic stop led to reasonable suspicion: “Here, based on Browne’s training and experience he identified indicators of suspected criminal activity including dark window tint, the evasive maneuver of pulling into the turnpike plaza and quickly reemerging, excessive nervousness, and Patterson’s contradictory statements regarding whether Browne had previously stopped him. While investigating the suspected criminal activity, Browne’s investigation into the initial purpose of the traffic stop, the window tint violation, was also ongoing.” State v. Patterson, 2025-Ohio-5671 (6th Dist. Dec. 19, 2025).*

No rational fact finder could find there was reasonable suspicion here, and the judgment is reversed. Hernandez v. State, 2025 Tex. Crim. App. LEXIS 946 (Dec. 19, 2025).*

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