Barnes v. State, 86 A.3d 1246

Two murders (Mr. Aidoo and Ms. Baah) occurred in January 2009; candle from Petitioner’s storage locker tied to threats to Aidoo.
Petitioner was detained and transported to a police station to execute DNA and fingerprint warrants; he later consented to locker search.
Suppression motion argued candle evidence was tainted fruit of unlawful detention; suppression court denied it.
Court of Special Appeals affirmed; Petitioner sought certiorari to challenge detention and consent issues.
Maryland Court of Appeals granted certiorari to address preservation and Fourth Amendment detention questions; majority affirms.
Petitioner ultimately convicted of two counts of first-degree murder and related offenses; candle admitted at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Petitioner unlawfully detained pre-consent to search?	Barnes argues detention before consent was de facto arrest without probable cause.	State argues delay was reasonable to complete warrants; no de facto arrest.	No de facto arrest; detention reasonable under total circumstances.
Was continued detention after warrant execution justified by reasonable suspicion?	Barnes contends continued detention lacked reasonable suspicion.	State asserts ongoing investigatory detention with reasonable suspicion.	Detention supported by reasonable suspicion; permissible timing after warrant.
Did consent to search locker taint from unlawful detention?	Consent tainted by unlawful detention and delays.	Consent obtained during lawful detention post-warrant; not tainted.	Consent was not tainted; search admissible.
Was the Fourth Amendment challenge properly preserved under Rule 8-504/8-303?	Petitioner properly presented unlawful detention/consent issues in appellate briefs.	State contends issues were not properly preserved.	Issues properly preserved; Court reaches merits.

Maryland v. Pringle, 540 U.S. 366 (U.S. 2003) (probable cause and detention standards for arrests)
Michigan v. Summers, 452 U.S. 692 (U.S. 1981) (extent of permissible detention during searches; exclusionary rule consequences)
Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (fruit of the poisonous tree doctrine; suppression of unlawfully obtained evidence)
United States v. Tilmon, 19 F.3d 1221 (7th Cir. 1994) (limits of arrest vs. investigatory detention)
Place, 462 U.S. 696 (U.S. 1983) (duration and intrusiveness of seizures in detentions)
Dunaway v. New York, 442 U.S. 200 (U.S. 1979) (arrest-like detention requires probable cause)
Bailey v. United States, 133 S. Ct. 1031 (S. Ct. 2013) (narrowing exceptions to probable cause for detentions)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (reasonableness of suspicion standard)
Cortez, 449 U.S. 411 (U.S. 1981) (reasonable suspicion standard; totality of circumstances)
Cartnail v. State, 359 Md. 272 (Md. 2000) (state-specific reasonable suspicion analysis)
Crosby v. State, 408 Md. 490 (Md. 2009) (limitations on investigatory detentions and questioning)
Murphy v. State, 379 Md. 231 (Md. 2004) (preservation and presentation of Fourth Amendment claims)