Anthony W. Brown v. State of Indiana (mem. dec.), 54A05-1605-CR-1087

On April 17, 2015, Officer Jerod Colley stopped a red 2010 Camaro after observing an illegal turn and learning the vehicle’s license plate was registered to a different car. The driver was Anthony Brown.
Brown could not produce valid registration or insurance; he gave a bill of sale and said he recently bought the Camaro.
Brown consented to a vehicle search and to a weapons pat-down. During the pat-down an officer discovered a plastic baggie containing a white powder later confirmed as methamphetamine. Brown admitted the substance was meth.
The State charged Brown with possession of methamphetamine (initially Level 6), later re-docketed to Level 5 based on a prior dealing conviction; the State also alleged habitual-offender status.
Brown filed a motion to suppress the meth evidence (arguing the stop was unlawfully prolonged); the trial court denied suppression, a jury convicted him, he pled guilty to the Level 5 enhancement and habitual-offender allegation, and the court imposed an aggregate executed 12-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of meth evidence recovered during stop	State: stop and subsequent actions were lawful; consent and officer safety justified pat-down and search	Brown: stop was unlawfully prolonged beyond mission (citing Rodriguez), so resulting search/seizure violated Fourth Amendment	Court: Stop was lawful and not unreasonably prolonged; questions and investigation into plate/registration justified actions; evidence admissible
Appropriateness of 12-year sentence	State: sentence supported by prior dealing conviction and extensive criminal history; enhancement and habitual-offender status justified term	Brown: sentence inappropriate given cooperation, recent legitimate work as a contractor, family responsibilities	Court: Sentence not inappropriate under App. R. 7(B); offender’s extensive criminal history and high risk to reoffend support sentence

Whren v. United States, 517 U.S. 806 (pretextual stops permissible where officer observes traffic violation)
Rodriguez v. United States, 575 U.S. _ (2015) (traffic stop cannot be prolonged beyond time reasonably required to complete mission)
Muehler v. Mena, 544 U.S. 93 (2005) (questioning during lawful detention does not itself constitute seizure)
Berkemer v. McCarty, 468 U.S. 420 (1984) (during traffic stop detainee need not answer questions; must be released unless probable cause arises)
Meredith v. State, 906 N.E.2d 867 (Ind. 2009) (officer’s on-the-spot evaluation need only reasonably suggest lawbreaking to justify stop)
Collins v. State, 966 N.E.2d 96 (Ind. Ct. App. 2012) (standard of review for evidentiary rulings)
Paul v. State, 888 N.E.2d 818 (Ind. Ct. App. 2008) (framework for Appellate Rule 7(B) sentence review)