US v. Perez, 2011 WL 304565, Docket No. 10-3063 (10th Cir. 2/1/11) (unpublished): A defense victory for the defendant charged with illegal possession of a sawed-off shotgun. The Tenth affirms the district court's suppression of a bullet found in the defendant's pocket. The district court held that the bullet was retrieved after the officer exceeded the permissible bounds of a protective frisk, and that without the bullet, the officer lacked probable cause to search the defendant's car, in which the shotgun was found