In United States v. Dubose, 579 F.3d 117, 119 (1st Cir. 2009), a law enforcement officer witnessed a defendant approach and lean into the front driver's side of a car "with both hands and his upper torso inside the vehicle."
A few moments later the defendant turned around and walked back the way he came. Id.
The First Circuit affirmed the district court's denial of a motion to suppress evidence resulting from the defendant's subsequent seizure, reasoning that the law enforcement officer had a sufficient reasonable suspicion that the defendant had engaged in a drug transaction because of the defendant's conduct and the fact that the whole encounter was "similar to the conduct involved in other drug transactions in the area." Id. at 121.