Brown v. United States, 313 A.3d 555

Daron Brown was stopped by police officers who believed he matched the description of a recent armed robbery suspect at a specific location.
Brown was handcuffed and frisked (first pat-down); no weapon was found initially.
Officers then asked Brown for identification; Brown attempted to reach for it but was told not to.
Officer Jones, at Brown's request, retrieved Brown's ID from his pocket, felt what seemed to be a gun, and then conducted a second pat-down in the area, discovering a firearm.
Brown moved to suppress the gun, arguing the search violated his Fourth Amendment rights; the trial court denied the suppression motion and he was convicted.
On appeal, the major issue was whether the second pat-down (and thus the discovery of the gun) depended on Brown's voluntary consent to the pocket search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of handcuffing/first pat-down	Officers exceeded scope of Terry stop by handcuffing	Officers acted reasonably due to safety risk	Handcuffing and first pat-down reasonable and lawful
Legality of pocket search	No voluntary consent given	Brown consented to the search	Remanded for trial court to find if consent was given
Legality of second pat-down	Second pat-down fruit of illegal (unconsented) pocket search	Discovery of gun during search justified second pat-down	Depends on validity of consent to pocket search

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes basic standard for stop and frisk based on reasonable suspicion)
Womack v. United States, 673 A.2d 603 (D.C. 1996) (handcuffing justified where suspect believed armed and dangerous)
Brown v. United States, 983 A.2d 1023 (D.C. 2009) (consent exception to Fourth Amendment exclusionary rule)
Wilson v. United States, 102 A.3d 751 (D.C. 2014) (suppression required for evidence derived from primary illegality unless taint purged)
Crews v. United States, 389 A.2d 277 (D.C. 1978) (government bears burden to show exception to exclusionary rule for tainted evidence)