Background

• Harrell was detained during an investigative stop by Sergeant Word after being seen with two pit bulls near Louisville Street.
• Harrell refused to provide his name and social security number and resisted follow-up instructions from the officer.
• Word eventually obtained Harrell’s information and issued an arrest citation for disorderly conduct and failure to obey commands.
• Municipal court and circuit court both convicted Harrell of the charged offenses after de novo trials; fines were imposed.
• Harrell challenged the stop as unlawful and sought suppression; the issue of suppression was dispositive.

Issues

Key Cases Cited

• Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (defines stop and reasonable suspicion standard)
• Singletary v. State, 318 So.2d 873 (Miss. 1975) (classification of police action into types including investigative stops)
• Eaddy v. State, 63 So.3d 1209 (Miss. 2011) (reasonable-suspicion standard for investigative stops)
• Brown v. Texas, 443 U.S. 47 (U.S. 1979) (limits on stop based on suspicion of crime)
• Reynolds v. City of Water Valley, 75 So.3d 597 (Miss. 2011) (fruit of the poisonous tree doctrine in unlawful stops)
• Trejo v. State, 76 So.3d 684 (Miss. 2011) (mixed standard of review for unlawful-seizure claims)
• Cady v. Dombrowski, 413 U.S. 433 (U.S. 1973) (community-caretaker function supporting police contact)
• Moore v. City of Louisville, 716 So.2d 1136 (Miss. Ct. App. 1998) (municipal authority to enforce public-safety ordinances)
• Floyd v. City of Crystal Springs, 749 So.2d 110 (Miss. 1999) (acknowledging community-safety policing context)