Maestas v. State, 416 P.3d 777

Traffic stop of Michael Maestas on June 25, 2016; Maestas tried to walk away and was handcuffed and asked to kneel.
Corporal Halter smelled marijuana, observed impairment, conducted a protective pat-down and found a pocket knife in Maestas’ right front pocket.
While removing the knife, Halter felt a "rock-like" object in the coin pocket and, believing it to be contraband based on his training and experience, seized it; it proved to be methamphetamine.
Halter then found a marijuana cigarette and a small baggie of hashish during a subsequent search.
Maestas moved to suppress the seized items as exceeding the scope of a Terry frisk and contending later items were fruit of the poisonous tree; the district court initially denied the motion, later made written findings on remand, and denied suppression.
Maestas entered a conditional guilty plea to marijuana possession (other charges dismissed) and appealed the suppression ruling; the Wyoming Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in denying Maestas' motion to suppress.	Halter exceeded Terry by seizing an item that was only suspected contraband; the incriminating character was not "immediately apparent," so the seizure and subsequent search were unlawful.	The seizure fell within the plain-feel/plain-view exception: Halter, during a lawful Terry frisk and while removing a knife, felt an object that his training and the totality of circumstances made immediately apparent as contraband, giving probable cause to seize and extend the search.	Affirmed — court held the seizure was justified under the plain-feel doctrine and probable cause considering totality of circumstances (odor, evasive conduct, location/feel of object, officer experience).

Terry v. Ohio, 392 U.S. 1 (permitting limited frisk for weapons during investigative stops)
Texas v. Brown, 460 U.S. 730 (plain-view doctrine requires object be "immediately apparent" as contraband)
Minnesota v. Dickerson, 508 U.S. 366 (plain-feel doctrine: seizure allowed if identity of contraband is immediately apparent by touch and search stays within Terry bounds)
Arizona v. Hicks, 480 U.S. 321 (additional manipulation to make incriminating character apparent violates Fourth Amendment)
Horton v. California, 496 U.S. 128 (plain-view seizure principles)
Coolidge v. New Hampshire, 403 U.S. 443 (plain-view principles and limitations)
Payton v. New York, 445 U.S. 573 (probable cause and seizure principles)
Ornelas v. United States, 517 U.S. 690 (probable cause assessed objectively under totality of circumstances)
Shores v. Lindsey, 591 P.2d 895 (Wyoming standard: trial court findings on suppression entitled to deference)
Commonwealth v. Zhahir, 751 A.2d 1153 (Pa. 2000) (considerations in plain-feel review: nature/location of object, suspect's conduct, officer experience)