Brumley v. Commonwealth, 413 S.W.3d 280

Late-night arrest of Randy Brumley outside his single-wide mobile home on a felony possession warrant; Brumley stepped outside voluntarily and was unarmed when taken into custody.
Officers had some prior information suggesting firearms might be inside the trailer.
While Brumley was being led away, officers heard a rustling/shuffling noise from inside the residence.
Several officers entered the trailer without a warrant to conduct a "protective sweep," discovered a dog as the noise source, and observed methamphetamine-manufacturing components in plain view.
Brumley was charged, his motions to suppress (warrantless search; chain of custody) were denied, he was convicted, the Court of Appeals affirmed, and the Kentucky Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers’ warrantless entry to perform a protective sweep met Buie’s second-category reasonable-suspicion standard	Brumley: sweep was unlawful because officers lacked articulable facts showing a hidden person posed a danger	Commonwealth: prior info of guns + noises from inside justified a protective sweep under Buie	Reversed: sweep unconstitutional — reasonable suspicion not established by the facts (guns + noise insufficient under totality)
Whether evidence seized during sweep was admissible absent a valid warrant	Brumley: evidence should be suppressed as fruit of an unlawful search	Commonwealth: evidence valid because sweep was protective and lawful	Moot after reversal of sweep: suppression warranted; chain-of-custody issue not reached

Payton v. New York, 445 U.S. 573 (U.S. 1980) (warrantless home entry to make an arrest is presumptively unreasonable)
Chimel v. California, 395 U.S. 752 (U.S. 1969) (scope of search incident to arrest limited to area within immediate control)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (reasonable suspicion standard for limited investigative stops)
Maryland v. Buie, 494 U.S. 325 (U.S. 1990) (two-category protective-sweep doctrine; broader sweeps require reasonable suspicion of a person posing danger)
Guzman v. Commonwealth, 375 S.W.3d 805 (Ky. 2012) (Kentucky adoption of Buie)
Kerr v. Commonwealth, 400 S.W.3d 250 (Ky. 2013) (Kentucky discussion applying Buie’s protective-sweep framework)
United States v. Archibald, 589 F.3d 289 (6th Cir. 2009) (protective-sweep analysis; courts have required articulable facts beyond poor lighting or vulnerability)
Humphrey v. Mabry, 482 F.3d 840 (6th Cir. 2007) (reasonable-suspicion assessed under totality of circumstances)
United States v. Atchley, 474 F.3d 840 (6th Cir. 2007) (approving sweep where officers observed a handgun and had other corroborating facts)