Eaddy v. State
2011 Miss. LEXIS 315
| Miss. | 2011Background
- Police stopped a red Cadillac with Texas plates in Port Gibson to locate Wendell Barnes, who had three arrest warrants; Eaddy was the driver who was arrested for possession of cocaine with intent to distribute and a weapon by a felon; the stop occurred during an informant-led effort tied to Barnes's warrants; the officer testified that he saw the butt of a gun under the driver's seat, smelled alcohol, and found two pill bottles containing cocaine during a protective search; Barnes was not in the car, and the arrest relied on warrants and a vague informant tip; the trial court denied the motion to suppress and Eaddy was convicted of possession with intent to distribute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying the motion to suppress | Eaddy argues warrants and informant tips did not create reasonable suspicion | State argues warrants/personal knowledge supported stop | Yes; suppression reversed and acquittal rendered |
Key Cases Cited
- Dies v. State, 926 So. 2d 910 (Miss.2006) (limits on review of Fourth Amendment facts; reasonable suspicion analysis)
- McClellan v. State, 34 So.3d 548 (Miss.2010) (valid investigatory stop based on corroborated informant information)
- Burchfield v. State, 892 So.2d 191 (Miss.2004) (reliance on informant tips with indicia of reliability)
- Haddox v. State, 636 So.2d 1229 (Miss.1994) (scope of investigatory stops; reasonable suspicion)
- Gonzales v. State, 963 So.2d 1138 (Miss.2007) (two-part inquiry for reasonableness of stop; scope)
- White v. State, 842 So.2d 565 (Miss.2003) (good-faith exception to exclusionary rule adopted; Leon framework)