Stafford v. State
59 A.3d 1223
| Del. | 2012Background
- Police stop car for tinted front windows; driver license status found suspended, and driver ready to be replaced by passenger.
- Passenger Byron Stafford provides false identity information, claiming name 'Daren Miller' with a Wilmington address and birth date.
- Stafford’s information yields no results in DELJIS after multiple name/address variations; officer has prior impersonation experience.
- Stafford is detained, questioned about weapons, handcuffed, and pat-searched; a firearm falls from his pant leg during the search.
- At the station, Stafford’s true identity is learned; DELJIS search reveals warrants; trial court denies suppression and convicts Stafford on multiple counts.
- Court holds probable cause to arrest for criminal impersonation; search incident to arrest valid; Delaware Constitution claim waived.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop and identification request lawful under the Fourth Amendment? | Stafford argues identification request exceeded scope of stop. | Stafford asserts he had rights to be free from frisk absent suspicion. | Stop/identify within scope; request lawful. |
| Did officers have probable cause to arrest Stafford for criminal impersonation? | Stafford asserts insufficient basis to impound based on impersonation. | Stafford contends DELJIS inconclusive; no probable cause for impersonation. | Probable cause existed to arrest for criminal impersonation. |
| May the firearm be seized in a search incident to a valid arrest? | Stafford argues search invalid absent sufficient basis for arrest. | Stafford relies on nonthreatening nature of offense to challenge search. | Firearm lawfully discovered during valid search incident to arrest. |
| Was Stafford's Delaware constitutional claim waived? | Stafford asserted rights under Delaware Constitution. | Stafford did not provide a reasoned Delaware constitutional challenge. | Claim waived; no Delaware constitutional error found. |
Key Cases Cited
- Holden v. State, 23 A.3d 843 (Del. 2011) (distinguishes when suspicion justifies frisk during traffic stop)
- United States v. Robinson, 414 U.S. 218 (Sup. Ct. 1973) (search incident to custodial arrest justified by safety rationale)
- Pringle, 540 U.S. 366 (Sup. Ct. 2003) (probable cause defined as reasonable ground for belief of guilt)
- Tolson v. State, 900 A.2d 639 (Del. 2006) (probable cause standard discussed and applied in Delaware)
- Maxwell, 624 A.2d 926 (Del. 1993) (probable cause described as fair probability beyond bare suspicion)