Deshawn Lamont Redfield v. State of Indiana, 78 N.E.3d 1104

Officer Bailey responded to an anonymous dispatch reporting a black male with a gun at the Birdhouse bar and arrived to see a person matching that description.
Bailey approached and spoke with Redfield and another man; he patted down the other man and informed them of the gun report.
While about five feet away, Redfield bladed his body away from Bailey and made a drawing motion with his right hand as if reaching for a gun; Bailey drew his service weapon and ordered Redfield to stop and show his hands.
Redfield ignored commands, walked ~50 feet, and Bailey deployed a taser; during the encounter Redfield grabbed a firearm from his waistband and Bailey tasered him again and secured the gun.
Officers found a loaded handgun (including a hollow-point) and crack cocaine on Redfield; he was charged with several offenses and moved to suppress the evidence as the product of an unlawful seizure under the Fourth Amendment and Article 1, Section 11 (Indiana Constitution).
The trial court admitted the evidence; Redfield was convicted and appealed, arguing the initial seizure was unlawful because there was no preexisting reasonable suspicion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Redfield)	Held
Whether Bailey unlawfully seized Redfield when he confronted/seized him absent preexisting reasonable suspicion	Officer Bailey’s seizure was reasonable because Redfield’s furtive movements and apparent drawing motion transformed a consensual encounter into a reasonable seizure for officer safety, and Redfield’s flight and noncompliance gave probable cause for arrest	Bailey had no reasonable suspicion at the time of the initial approach; the anonymous tip alone did not justify seizure or frisk, so subsequent discoveries were fruit of an unlawful seizure	Court held the encounter was nonseizure initially but became a lawful seizure when Redfield’s sudden conduct (blading away and drawing motion) reasonably created officer safety concerns; later flight provided probable cause; convictions affirmed

Ornelas v. United States, 517 U.S. 690 (1986) (standards for appellate review of reasonable suspicion and probable cause determinations)
McIlquham v. State, 10 N.E.3d 506 (Ind. 2014) (state standard for reviewing search and seizure questions and sufficiency review)
United States v. Ellis, 501 F.3d 958 (8th Cir. 2007) (officer may search after consensual encounter becomes suspicious when defendant makes furtive/arm-reaching gestures)
Commonwealth v. Stephens, 885 N.E.2d 785 (Mass. 2008) (consensual encounter permissibly escalated to search when officer observed quick movements suggesting concealment of weapon)
Guilmette v. State, 14 N.E.3d 38 (Ind. 2014) (distinguishing appeals from suppression-motion denials and review standards for admission of evidence)
Wilkins v. State, 946 N.E.2d 1144 (Ind. 2011) (waiver of state-constitutional claim when no independent analysis is presented)