State of Tennessee v. Christopher Douglas Smith
W2015-01826-CCA-R10-CD
| Tenn. Crim. App. | Mar 14, 2017Background
- Defendant Christopher Douglas Smith was indicted on multiple drug- and weapon-related counts stemming from events on Dec. 14, 2014 and Mar. 12, 2015; this appeal concerns suppression of evidence seized Mar. 12, 2015.
- Investigator Joey Hedge obtained a search warrant for Defendant’s house on March 12, 2015 based largely on information from a confidential informant (CI) and included facts from a prior December 2014 search that yielded methamphetamine.
- After the CI reported Defendant had methamphetamine in his pocket that day, officers located Defendant and his companion (Tonya Swafford) in a parking lot; Investigator Hedge pulled in front of their car to block it and handcuffed Defendant after confronting him.
- Officers searched Swafford’s purse after she told them she had “what you want,” finding methamphetamine; Swafford later consented in writing to a search of the vehicle, which yielded hydrocodone pills.
- Investigator Hedge then performed a second pat-down of the handcuffed Defendant and seized 30.2 grams of methamphetamine, cash, a phone, and marijuana; Defendant’s motion to suppress these items (all but the hydrocodone) was granted by the trial court.
- The State obtained an extraordinary appeal; the Court of Criminal Appeals reversed, holding probable cause supported a warrantless arrest (and alternatively that inevitable discovery applied).
Issues
| Issue | State's Argument | Smith's Argument | Held |
|---|---|---|---|
| Validity of search incident to arrest | Officer had probable cause to arrest Smith for felony methamphetamine possession based on CI tip, prior investigation, and officer observations, so seizure/search incident to arrest was lawful | The encounter was an unlawful Terry stop/frisk; officers detained and searched Smith without reasonable suspicion or probable cause | Reversed suppression: probable cause existed for arrest; search incident to arrest valid (also noted inevitable discovery alternative) |
| Reliability of CI information | CI had basis of knowledge (personal observation that Smith had a golf-ball sized meth) and strong reliability (prior successful tips and a magistrate-issued warrant) | Argued stop/frisk framework applies; challenged detention/search as improper under Terry | CI met Aguilar-Spinelli prongs and, combined with officer observations, supplied probable cause |
| Whether encounter was a seizure versus consensual encounter | Officers’ blocking of vehicle and handcuffing restrained Smith; but probable cause rendered arrest lawful | Characterized as an improper seizure/frisk lacking justification | Court treated the restraint as an arrest requiring probable cause and found probable cause present |
| Applicability of inevitable discovery doctrine | Even if arrest lacked probable cause, evidence would have been inevitably discovered after lawful search of vehicle based on Swafford’s consent and arrest for hydrocodone | Not argued by Smith in opposition | Court endorsed inevitable discovery as an alternative basis for admitting the seized items |
Key Cases Cited
- Beck v. Ohio, 379 U.S. 89 (probable cause standard for warrantless arrest)
- Nix v. Williams, 467 U.S. 431 (inevitable discovery doctrine)
- State v. Echols, 382 S.W.3d 266 (Tenn. 2012) (warrantless arrest exception to warrant requirement)
- State v. Bishop, 431 S.W.3d 22 (Tenn. 2014) (objective seizure analysis; officer’s subjective intent irrelevant)
- State v. Yeargan, 958 S.W.2d 626 (Tenn. 1997) (warrantless search presumptively unreasonable; State bears burden to show exception)
- State v. Jacumin, 778 S.W.2d 430 (Tenn. 1989) (Aguilar-Spinelli application to CI-based probable cause)