People v. Thomas, 29 Cal. App. 5th 1107

In April 2016 a 911 caller reported a "male black adult" in a gray hooded sweatshirt and black pants was "harassing" customers and had "set up camp"; no threats, weapons, or specific crimes were reported.
Officers arrived about 2 hours 20 minutes after the call and found defendant seated on the sidewalk ~70–80 yards from the business, wearing multiple layers on a warm day; no other people were nearby.
Officers asked for identification; defendant refused to give his name and began to walk away. Officers restrained him, handcuffed him, and conducted a Terry patsearch.
During the patsearch officers felt and recovered a fixed-blade knife and a narcotics pipe; an EBT card revealed defendant was on informal searchable probation; methamphetamine was later found.
Defendant moved to suppress the detention and patsearch under Penal Code §1538.5; the magistrate denied the motion, defendant was convicted at trial, and appealed.
The appellate court reversed, holding the initial detention and frisk were not supported by reasonable suspicion and the probation-search exception could not justify the search because officers did not know of the probation condition prior to the search.

Issue	People's Argument	Thomas's Argument	Held
Whether officers had reasonable suspicion to detain (Terry stop) Thomas after a vague harassment call and his refusal to ID	The 911 call plus Thomas's attire, behavior, refusal to ID, and walking away provided reasonable suspicion	The call was stale (2+ hours), vague, and did not describe criminal conduct; refusal to ID does not create reasonable suspicion	No reasonable suspicion: general, stale description and refusals insufficient to detain
Whether frisk/patsearch for weapons was justified	Frisk justified by behavior, clothing, and refusal to cooperate	No articulable facts suggested Thomas was armed or dangerous	No: no specific facts supported a weapons frisk
Whether the probation-search doctrine could validate the search	Once officers learned Thomas was on searchable probation, the search was inevitable; Thomas's denial of probation estops him from challenging the search	Officers did not know of probation condition before detaining/searching; estoppel was not argued below	Forfeited estoppel; in any event probation exception inapplicable because officers lacked advance knowledge of the search condition
Remedy for erroneously denied suppression motion	Evidence would be admissible if search lawful	Suppress fruits of unlawful stop/search	Motion to suppress should have been granted; convictions reversed and remanded

Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable-suspicion standard for investigative stops and frisk)
In re Tony C., 21 Cal.3d 888 (1978) (stop requires specific and articulable facts that some criminal activity occurred or is occurring)
In re Jaime P., 40 Cal.4th 128 (2006) (probation-search exception requires officer knowledge of search condition at time of search)
People v. Hoeninghaus, 120 Cal.App.4th 1180 (2004) (same—probation exception inapplicable if officers unaware of search condition)
People v. Watkins, 170 Cal.App.4th 1403 (2009) (equitable estoppel may bar suppression when defendant intentionally misleads about identity/probation status)
Florida v. Royer, 460 U.S. 491 (1983) (refusal to answer questions or provide ID does not alone justify detention)
Illinois v. Wardlow, 528 U.S. 119 (2000) (flight from police in high-crime area can contribute to reasonable-suspicion analysis)