State of Louisiana v. Joseph Michael Moultrie, 224 So. 3d 349

Police found ~2 ounces of crack cocaine inside a barbecue grill in a driveway between two trailers after encountering defendant standing in the street at ~11 p.m. in a high-crime neighborhood.
Defendant briefly retreated into the driveway when officers arrived; officers observed torn baggies with suspected drug residue on the ground.
Officers saw a grill with its lid slightly ajar and disturbed dew on the handle; they opened it and discovered the cocaine.
Defendant claimed the trailer was his mother’s, that the grill belonged to the family, denied knowledge of the cocaine, and argued that it was on his property.
At trial defendant was convicted for possession with intent to distribute; on appeal he challenged the denial of his motion to suppress and later the sufficiency of the evidence.
The Louisiana Supreme Court held defendant failed to show a reasonable expectation of privacy in the grill, reversed the court of appeal’s suppression ruling, and remanded for a sufficiency review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion to stop/question defendant and perform a limited search	Stop/search justified by time, location (high-crime area), defendant’s furtive movement when officers arrived, and nearby drug paraphernalia	Stop/search unlawful; search of the grill exceeded permissible protective scope absent warrant or clear justification	Court agreed there was reasonable suspicion to stop/question; officers could conduct protective inquiry at scene
Whether defendant had a reasonable expectation of privacy in the barbecue grill, making the warrantless search unconstitutional	State argued defendant lacked reasonable expectation of privacy in the grill (open, on property, not shown to belong to defendant) and search was permissible for officer safety/evidence prevention	Defendant argued he had privacy/ownership ties (claimed family ownership and property control) so search violated the Fourth Amendment and La. Const. art. I, § 5	Court held defendant failed to meet initial threshold of showing a reasonable expectation of privacy in the grill; search need not be suppressed and case remanded to review evidence sufficiency

Terry v. Ohio, 392 U.S. 1 (1968) (officers may take measures to neutralize threat when suspect may be armed)
Minnesota v. Dickerson, 508 U.S. 366 (1993) (limited search incident to investigatory stop framework)
United States v. Salvucci, 448 U.S. 83 (1980) (defendant bears initial burden to show expectation of privacy)
State v. Perry, 502 So.2d 543 (La. 1986) (La. Const. privacy test follows Fourth Amendment reasonable-expectation standard)
State v. Burkhalter, 428 So.2d 449 (La. 1983) (review considers totality of evidence from suppression hearing and trial)