Chandler Turner v. State of Indiana (mem. dec.)
49A02-1602-CR-229
| Ind. Ct. App. | Nov 10, 2016Background
- Officer Faulk, acting on a detective's tip that "Chandler" sold drugs from a black Toyota, located an African‑American man (Chandler Turner) near a black Toyota on Roberta Drive.
- Faulk confirmed his identity, learned he was on house arrest away from permitted locations, asked to pat him down, and Turner consented.
- After finding nothing on Turner, Faulk handcuffed him without objective justification to prevent flight.
- While Turner was handcuffed, Faulk looked through the driver’s door window, saw a container with two burn marks on the lid, opened the door, removed the lid, and found cocaine and marijuana.
- Turner moved to suppress the drugs under the Fourth Amendment and Article 1, § 11 (Indiana Constitution); the trial court denied the motion, he was convicted, and he appealed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Turner) | Held |
|---|---|---|---|
| Were Turner’s Fourth Amendment rights violated by the initial handcuffing and should the drugs be excluded? | Handcuffing was an unlawful but separable act; the drugs were discovered independently, so exclusion is not required. | Handcuffing was unlawful and tainted the discovery/seizure of the drugs, requiring exclusion. | Court: Handcuffing violated the Fourth Amendment, but the drugs were discovered independently (no but‑for causation), so exclusion was not warranted. |
| Did Faulk’s warrantless search/seizure of the container inside the car violate the Fourth Amendment or fall within an exception? | The container was in open view and the burn marks gave probable cause that it was drug paraphernalia, invoking the automobile exception. | The burn marks did not provide probable cause to believe the container was used for drugs. | Court: Officer’s training/experience supported probable cause from the burn marks; automobile exception justified the seizure. |
| Does Article 1, § 11 of the Indiana Constitution independently bar admission of the drugs? | State: Article 1, § 11 does not bar admission because discovery/seizure was independent of the illegal handcuffing and the subsequent search was reasonable under exceptions. | Turner: Indiana constitutional protection requires suppression because of the unlawful initial seizure and intrusion. | Court: Turner’s Article 1, § 11 claim fails because he does not contest the lawfulness of Faulk’s actions at the car; discovery was untainted by the earlier illegality. |
Key Cases Cited
- Davis v. United States, 564 U.S. 229 (exclusionary rule is a deterrent sanction separate from whether a Fourth Amendment violation occurred)
- Hudson v. Michigan, 547 U.S. 586 (exclusionary rule applies only when evidence was obtained as a result of the constitutional violation)
- Florida v. Harris, 133 S. Ct. 1050 (probable cause defined by whether facts warrant a person of reasonable caution to believe contraband or evidence is present)
- Garcia v. State, 47 N.E.3d 1196 (Indiana standard of review for constitutional search and seizure claims)
- Clark v. State, 994 N.E.2d 252 (general warrant requirement for searches)
- Thurman v. State, 602 N.E.2d 548 (automobile exception allows warrantless seizure of contraband in open view)
- Litchfield v. State, 824 N.E.2d 356 (Indiana’s independent Article 1, § 11 analysis requires balancing intrusion, suspicion, and law enforcement needs)