This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A police officer responded to an anonymous 911 call reporting a gun-related incident near a school. The officer encountered the appellant, a juvenile, and his companion near a Laundromat in the vicinity of the reported crime. The officer observed the appellant acting nervously, with his hands in his jacket pockets, and conducted a patdown, discovering a revolver, marijuana, and drug paraphernalia. The appellant sought to suppress the evidence, arguing the officer lacked reasonable suspicion for the seizure and search (paras 1-7).
Procedural History
- District Court, San Juan County: Denied the appellant's motion to suppress evidence, finding the officer's actions justified based on the reported gun incident and the appellant's behavior (paras 11-12).
Parties' Submissions
- Appellant: Argued that the officer lacked reasonable suspicion to seize and search him, as the information from the 911 call was insufficient and the appellant's behavior did not justify the detention (paras 8-9, 12-13).
- Respondent: Contended that the officer had reasonable suspicion based on the appellant's proximity to the reported crime, his nervous and evasive behavior, and the need for officer safety (paras 9, 19, 23).
Legal Issues
- Did the officer have reasonable suspicion to seize the appellant under the Fourth Amendment?
- Was the evidence obtained during the patdown search admissible?
Disposition
- The Court of Appeals reversed the district court's denial of the motion to suppress and remanded the case for further proceedings (para 25).
Reasons
Per Sutin J. (Fry CJ. and Bustamante J. concurring):
The court determined that the appellant was seized when the officer instructed him to remove his hands from his pockets, as a reasonable person would not feel free to leave under such circumstances (paras 19-20). The court held that the officer lacked the requisite reasonable suspicion to justify the seizure, as the appellant's proximity to the reported crime and his nervous behavior were insufficient to establish individualized suspicion of criminal activity (paras 21-24). Consequently, the evidence obtained during the patdown was unlawfully obtained and should have been suppressed (para 24).