State of Missouri v. Derrick L. Carrawell, 481 S.W.3d 833

Officers approached a neighborhood investigating gang complaints; Carrawell exited his car, made obscene gestures and verbal threats, and produced a white plastic grocery bag.
Officer Burgdorf announced Carrawell was under arrest for peace disturbance; Carrawell walked away, clutched the bag, and resisted the officer’s attempts to restrain him.
During the struggle Burgdorf ripped the bag from Carrawell; it hit the ground and made a breaking sound; Carrawell was handcuffed and placed in the patrol car.
After securing Carrawell in the squad car, Burgdorf opened the bag and found a broken ceramic plate and a smaller bag with heroin; Carrawell was charged with possession.
Carrawell moved to suppress the heroin arguing the arrest lacked probable cause for peace disturbance and the warrantless search of the bag was not justified (not incident to arrest, not inventory or exigent).
Trial court denied the motion; Carrawell was convicted and appealed; the court affirmed, holding the arrest lawful (resisting arrest) and the bag-search unlawful but admissible under a good-faith reliance exception to the exclusionary rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawfulness of arrest	Carrawell: No probable cause for peace disturbance; arrest unlawful	State: Probable cause existed at least for resisting arrest based on flight and physical resistance	Arrest lawful — probable cause for resisting arrest justified the seizure
Search-incident-to-arrest scope	Carrawell: Bag was not within immediate control when searched; Chimel/Gant bar the search	State: Bag was in Carrawell’s possession at arrest or within officer’s authority to inspect for safety	Search was not a valid search-incident-to-arrest because bag was not within immediate control at time of search
Exigent / other warrant exceptions	Carrawell: No probable-cause-based exigency or inventory rule basis shown	State: Officer feared weapon/danger from bag; appellate precedent allowed searching personal effects	No exigent- or inventory-based justification proven; search unlawful under Fourth Amendment
Exclusionary rule application	Carrawell: Illegally obtained evidence should be suppressed	State: Officers reasonably relied on existing court-of-appeals precedent permitting such searches; good-faith exception applies	Exclusionary rule does not apply due to objectively reasonable reliance on then-binding appellate precedent; evidence admissible

Illinois v. Krull, 480 U.S. 340 (1987) (exclusionary rule and exceptions discussion)
Katz v. United States, 389 U.S. 347 (1967) (warrantless searches presumptively unreasonable)
United States v. Robinson, 414 U.S. 218 (1973) (search incident to lawful arrest of person and effects)
Chimel v. California, 395 U.S. 752 (1969) (limits search-incident-to-arrest to area within immediate control to prevent access to weapons or destruction of evidence)
United States v. Chadwick, 433 U.S. 1 (1977) (containers under exclusive police control not searchable as incident to arrest)
Arizona v. Gant, 556 U.S. 332 (2009) (vehicle-search limits; Chimel rationale reaffirmed)
United States v. Edwards, 415 U.S. 800 (1974) (narrow holding about searching arrestee’s clothing at stationhouse)
Riley v. California, 573 U.S. 373 (2014) (Chimel rationales govern cell-phone search issue; emphasized case-specific analysis)
Devenpeck v. Alford, 543 U.S. 146 (2004) (officer’s subjective intent need not match legal justification for arrest)
Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule not triggered when officers reasonably rely on binding precedent)
State v. Johnson, 354 S.W.3d 627 (Mo. banc 2011) (Missouri application of good-faith reliance on appellate precedent)
State v. Rutter, 93 S.W.3d 714 (Mo. banc 2002) (standards for inevitable discovery/inventory exceptions)
State v. Heitman, 589 S.W.2d 249 (Mo. banc 1979) (probable cause defined for arrests)