People v. Lightfoot

In People v. Lightfoot (124 AD3d 802 [2d Dept 2015]) the police were entitled to engage in a level three forcible stop and detention of the defendant who also smelled of marihuana because the police also possessed reasonable suspicion that the defendant had just committed a "crime," not merely a violation. In Lightfoot, the officer reasonably believed that the defendant had been trespassing in a dwelling (i.e., criminal trespass in the second degree, Penal Law 140.15, a class A misdemeanor).