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Although it's common to see the term "stop and frisk," it's possible that there might be justification for a stop, but not for a frisk.
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Unfortunately, Officer Erfle will not be the last law enforcement officer who will fall victim to a bad guy carrying a concealed firearm. The reason is simple; unless you have cause to search, you really can't tell who is packing and who isn't.
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Every year officers are disarmed and murdered with their own weapons. It only makes sense to always carry while off duty and to always carry a back-up weapon while on duty.
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