Floyd Weddle v. State of Indiana, 989 N.E.2d 371

Weddle was subject to an arrest warrant for theft and false informing; officers suspected meth manufacture at his residence.
Officers knocked, announced, saw movement inside, and entered; Weddle was detained.
Officers heard additional movement in the back; Hall was found in a bedroom, Burton later arrested on a Johnson County warrant.
Protective sweep conducted to ensure safety, moving through adjoining rooms; surveillance of a back area revealed a hidden Burton.
A search warrant was obtained after consent to search was denied, yielding meth precursors, liquids, solvents, pseudoephedrine, and marijuana plants.
Weddle moved to suppress the evidence; trial court denied; conviction followed, with a partial vacatur on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the protective sweep and subsequent search reasonable under the Fourth Amendment?	Weddle contends sweep was impermissibly broad.	State argues Buie framework allows rooms adjoining arrest area with articulable risk.	Protective sweep reasonable; evidence admitted.
Was the protective sweep reasonable under Article I, Section 11 of the Indiana Constitution?	Indiana constitutionality argued against sweep scope.	Totality-of-circumstances supports reasonable intrusion and safety concerns.	Indiana Constitution permits the sweep; evidence admitted.

Maryland v. Buie, 494 U.S. 325 (1990) (defines scope of protective sweeps and immediate-adjacent areas)
State v. Estep, 753 N.E.2d 22 (Ind. Ct. App. 2001) (allowance of breaking doors within arrest context; protective sweep framework)
Hannibal v. State, 804 N.E.2d 206 (Ind. Ct. App. 2004) (protective sweep when there is specific danger; circumstances justify scope)
United States v. Brown, 64 F.3d 1083 (7th Cir. 1995) (Buie guidance applied to adjacent rooms in protective sweep)
United States v. Tapia, 610 F.3d 505 (7th Cir. 2010) (ambush risk outweighed by safety concerns in protective searches)