Daniel J. Glasgow v. State of Indiana, 99 N.E.3d 251

Around midnight officers found two men (Glasgow and Hunt) with disabled vehicles on the road shoulder; officers stopped to offer assistance.
Officers learned both men had suspended licenses but did not arrest them; while waiting, Hunt bent down behind an open car door and Officer Butcher found a jewelry box containing suspected heroin nearby.
Hunt denied ownership of the box and was handcuffed and placed in a patrol car; officers then told Glasgow he was not free to leave.
Before patting Glasgow down, Officer Butcher asked if Glasgow had any needles or weapons; Glasgow responded he had a syringe, removed it from his pocket, and placed it on the car hood.
Trial court suppressed heroin Glasgow placed on the hood later but admitted the syringe; after a bench trial Glasgow was convicted of unlawful possession of a syringe (Level 6) and received an aggregate four-year sentence (with habitual offender admission).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Glasgow)	Held
Whether the officers’ stop/ detention was lawful under the Fourth Amendment and Indiana Constitution	Stop became a valid Terry stop after officers discovered suspected heroin near where Hunt knelt, giving reasonable suspicion to detain and investigate both men	Stop and subsequent patdown were unlawful—officers lacked reasonable suspicion and the encounter was nonconsensual, so seizure violated Fourth Amendment and art. I, §11	The stop was lawful; discovery of heroin and furtive conduct provided reasonable suspicion, and Indiana balancing also supported the stop
Whether the syringe was the product of an unlawful search (patdown) and inadmissible	Syringe was admissible because it was voluntarily produced in response to a safety question asked during a lawful stop; not the fruit of a patdown	Syringe should be suppressed as the product of an unconstitutional search/seizure	The syringe was admissible: officers lawfully asked about needles/weapons during the Terry stop and Glasgow produced the syringe before any search

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigative stop and limited weapons search rule)
Mitchell v. State, 745 N.E.2d 775 (Ind. 2001) (Indiana interprets art. I, §11 independently of federal Fourth Amendment)
Holder v. State, 847 N.E.2d 930 (Ind. 2006) (art. I, §11 reasonableness test balancing suspicion, intrusion, and law enforcement need)
Finger v. State, 799 N.E.2d 528 (Ind. 2003) (nervousness can contribute to reasonable suspicion; limits on detention duration)
Lockett v. State, 747 N.E.2d 539 (Ind. 2001) (police may routinely inquire about weapons/needles for officer safety)
Jacobs v. State, 76 N.E.3d 846 (Ind. 2017) (de novo review applies when admissibility turns on constitutional search-and-seizure questions)
Washington v. State, 784 N.E.2d 584 (Ind. Ct. App. 2003) (trial court discretion on admissibility rulings standard)