Christpher A. Coyle v. State of Indiana (mem. dec.)
62A04-1608-CR-1887
| Ind. Ct. App. | Sep 6, 2017Background
- U.S. Marshals pinged fugitive Chad Posey’s cell phone to Christopher Coyle’s rural property; officers from multiple agencies converged to execute felony arrest warrants for Posey.
- Officers saw Posey in Coyle’s backyard; Posey fled on an ATV toward/into nearby woods; officers approached the property from front and rear.
- Deputy Damion Marsh swept the yard perimeter and briefly looked around a shed while searching for Posey; he observed an open zippered bag in plain view containing items (salt, rubbing alcohol, camouflage fuel can) he associated with meth manufacture.
- Marsh asked Coyle for consent to search; Coyle refused. Marsh and Officer Biever used the plain-view observations to secure a search warrant.
- Troopers executed the warrant and found items inside and outside the home consistent with drug activity. Coyle was charged with multiple drug-related offenses and moved to suppress the evidence; the trial court denied the motion and certified an interlocutory appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Deputy Marsh’s warrantless entry/search of Coyle’s property violated the Fourth Amendment | Marsh had no legal basis to remain/search the property after Posey fled; the shed inspection was a warrantless, unlawful search that produced evidence used for the warrant | Officers had probable cause that Posey was on the property, were executing arrest warrants, and Marsh’s brief perimeter/protective sweep and plain-view observations were reasonable | Search was reasonable under the Fourth Amendment; denial of suppression affirmed |
| Whether the search violated Article 1, Section 11 of the Indiana Constitution | Same: state action was an unreasonable intrusion and the evidence was fruit of an unconstitutional search | Under the totality of circumstances, intrusion was limited, officers reasonably believed a fugitive was present, and plain-view discovery justified the warrant application | Search was reasonable under Article 1, Section 11; denial of suppression affirmed |
Key Cases Cited
- Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (exigency exception permits warrantless searches when needs of law enforcement are compelling)
- Maryland v. Buie, 494 U.S. 325 (U.S. 1990) (definition and limits of a "protective sweep")
- Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (standard of review for suppression rulings and expectation-of-privacy analysis)
- Myers v. State, 839 N.E.2d 1146 (Ind. 2005) (framework for evaluating searches under Indiana Constitution)
- Kelly v. State, 997 N.E.2d 1045 (Ind. 2013) (search constitutionality reviewed de novo)
- Scott v. State, 803 N.E.2d 1231 (Ind. Ct. App. 2004) (upholding limited protective sweep during execution of arrest warrant)