Amondo Stewart a/k/a Amondo DeCharles Stewart v. State of Mississippi, 367 So.3d 985

Forrest County officers investigating a missing-person report approached a tent where Stewart (aka "Detroit") was staying and asked occupants to exit; Stewart and the missing person agreed to move to a parking lot to talk.
Officer Nate Robertson spoke with Stewart, then asked if Stewart would accompany him to the station for a recorded interview; Stewart—without a car—agreed and Robertson offered a “courtesy ride.”
Before transport, Robertson asked whether Stewart had any contraband because inmates may be criminally charged for bringing contraband into jail; Stewart pulled open his pants and revealed a clear baggie tucked in his underwear.
Robertson retrieved the bag, observed a crystalline substance, placed Stewart into custody, and testing later confirmed 4.835 grams of methamphetamine.
At trial the jury heard only Robertson’s testimony and a forensic chemist’s identification of meth; Stewart did not move to suppress, object at trial, or raise the issues in post-trial motions.
On appeal Stewart argued the seizure and his statements violated the Fourth Amendment and Miranda; the Mississippi Supreme Court found those claims waived, declined plain-error reversal on the sparse record, and affirmed his conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment: seizure/search of meth	Stewart: drugs were obtained by an illegal, nonconsensual search beyond scope of investigatory stop	State: Stewart voluntarily revealed the bag during a consensual interaction; no warrantless search beyond scope occurred	Court: Waived for failure to object; on plain-error review record shows no obvious Fourth Amendment violation; upheld admission
Fourth Amendment: voluntariness/consent to seizure	Stewart: did not voluntarily consent to search/seizure	State: Stewart cooperated and showed the drugs; no refusal or coercion presented	Court: No plain error; testimony supports voluntariness and lawful seizure
Miranda: custodial interrogation	Stewart: his answers were elicited while not free to leave, triggering Miranda protections	State: Stewart was not in custody when questioned and thus Miranda did not apply; his admission was non-custodial and investigatory	Court: Waived; record supports that Stewart was not in custody until after he revealed the drugs, so Miranda did not attach
Procedural default / plain-error review	Stewart: raises constitutional errors on appeal	State: Issues were waived by failure to move to suppress or object at trial; appellate review should be barred	Court: Issues are procedurally barred; Stewart only raised plain error in reply brief; Court found no plain, obvious error on undeveloped record and affirmed

Terry v. Ohio, 392 U.S. 1 (1968) (authorizes limited investigative stops and seizures to resolve ambiguities)
Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires Miranda warnings)
Rhode Island v. Innis, 446 U.S. 291 (1980) (definition of interrogation includes words or actions police should know likely to elicit incriminating response)
Shinstock v. State, 220 So. 3d 967 (Miss. 2017) (failure to object at trial bars appellate challenge; discusses waiver and plain-error doctrine)
Gales v. State, 153 So. 3d 632 (Miss. 2014) (voluntary revelation of an object can end reasonable expectation of privacy)
Eaddy v. State, 63 So. 3d 1209 (Miss. 2011) (scope of search must relate to circumstances that justified the stop)
Porter v. State, 616 So. 2d 899 (Miss. 1993) (noncustodial investigatory questioning does not require Miranda warnings)