Chase v. State, 144 A.3d 630

Background

In Sept. 2013 Baltimore County Vice/Narcotics detectives observed a Jeep Cherokee parked outside a Days Inn in a neighborhood known for drug trafficking; a Lexus pulled in and its driver entered the Jeep for a brief interaction.
Detectives approached, observed furtive movements (reaching under a seat, passenger putting hand in pocket), detained both occupants, and placed them in handcuffs for officer safety.
A K‑9 arrived within minutes, alerted on the Jeep, and after questioning one occupant became unresponsive; detectives then arrested Ira Chase, searched him incident to arrest, and found a motel room key.
Police obtained a warrant for the motel room tied to the key; the room search produced 138 grams of cocaine and paraphernalia.
Chase moved to suppress, arguing (1) reasonable suspicion of drug activity alone does not justify a belief he was armed and dangerous; (2) placing him in handcuffs converted the Terry stop into an arrest without probable cause; and (3) continued handcuffing after a frisk that revealed no weapons converted the detention into an unlawful arrest. Trial court denied suppression; convictions affirmed by intermediate appellate court; Court of Appeals affirmed.

Issues

Issue	Chase's Argument	State's Argument	Held
Whether reasonable suspicion of drug activity alone equals reasonable suspicion that suspect is armed and dangerous	Drug-activity suspicion alone is insufficient to support belief suspect is armed and dangerous	Totality (high-crime area, furtive movements, officer training) provided particularized facts supporting belief weapons might be present	No; drug activity alone normally insufficient, but here particularized furtive movements plus context supplied reasonable suspicion that suspect might be armed
Whether handcuffing Chase when removed from vehicle converted stop into an arrest requiring probable cause	Handcuffs automatically converted the intrusion into an arrest absent probable cause to arrest	Handcuffs were reasonably necessary for officer safety given observed furtive movements and proximity of unsearched vehicle	Use of handcuffs did not automatically convert the stop to an arrest; here handcuffing was justified as part of a Terry stop for officer safety
Whether continued handcuffing after a frisk that revealed no weapons converted detention into an arrest while awaiting the K‑9	Once frisk revealed no weapons, continued restraint was no longer justified and became an arrest without probable cause	Officers reasonably feared weapons might still be in the unsearched vehicle; brief continued restraint pending vehicle/K‑9 search was justified	Continued handcuffing did not convert the detention into an arrest because officer safety concerns persisted (unsearched vehicle, ongoing investigation, short duration)
Admissibility of evidence seized from motel room as fruit of an unlawful arrest	Evidence is fruit of unlawful arrest and should be suppressed	Evidence was obtained after a valid Terry stop, K‑9 alert, arrest and valid warrant; thus admissible	Evidence admissible; suppression denial affirmed

Key Cases Cited

Terry v. Ohio, 392 U.S. 1 (establishing investigatory stop and frisk standard when officer reasonably believes person is armed and dangerous)
Pennsylvania v. Mimms, 434 U.S. 106 (officer safety can justify ordering driver out of vehicle during lawful stop)
Quince v. State, 319 Md. 430 (particularized reports that a person is armed can justify a frisk)
Derricott v. State, 327 Md. 582 (drug‑courier profile alone insufficient to justify frisk for weapons)
Smith v. State, 345 Md. 460 (frisk limited to discovering weapons; avoid more intrusive searches)
Ransome v. State, 373 Md. 99 (officer must articulate particularized facts to justify stop and frisk)
Dashiell v. State, 374 Md. 85 (officer experience that drug traffickers carry weapons is a factor but generally insufficient alone)
Cotton v. State, 386 Md. 249 (handcuffing during execution of dangerous‑premises warrant does not automatically create de facto arrest)
Williamson v. State, 398 Md. 489 (detention of occupant near premises being searched can be justified by proximity and officer safety)
Longshore v. State, 399 Md. 486 (placing suspect in handcuffs during a stop can convert it into an arrest when no safety justification exists)
Crosby v. State, 408 Md. 490 (reasonable suspicion assessed under totality of circumstances; courts must defer to officer training/experience)
In re David S., 367 Md. 523 (handcuffing during a stop did not convert it to arrest where officer had reasonable belief of threat to safety)