State of Washington v. Brian Palacios-Farias, 33777-4

Police responded to a trailer park burglary report describing three masked males in black; officers later saw a silver Mustang leave the scene and traced it to apartment A-104.
Officers observed curtains open/close at A-104 and heard a rear door open with a "thump." Palacios-Farias was seen running from the backyard toward the open back door and was handcuffed after being ordered to the ground.
Officers told him he was not under arrest while they investigated; Palacios-Farias denied living in the apartment and denied owning a nearby backpack.
Officers found a dry black backpack near the fence on wet ground; nobody claimed it. The backpack contained school items with another suspect’s name, electronics, and duct tape.
After being advised of Miranda rights, the juveniles and Palacios-Farias made statements and were then formally arrested for possession of stolen property. Palacios-Farias was charged with residential burglary and second-degree theft.
Pretrial CrR 3.5 (statements) and CrR 3.6 (search) suppression motions were denied; he appealed those denials.

Issue	Palacios-Farias's Argument	State's Argument	Held
Whether statements made while handcuffed required Miranda warnings (i.e., whether he was under arrest)	He was under arrest once handcuffed, so pre-Miranda denials should be suppressed	Detention was a lawful Terry stop; handcuffing was reasonable for officer safety and not a formal arrest	Court held it was a lawful Terry stop; handcuffing permitted given safety concerns; pre-Miranda statements admissible
Whether the backpack search required a warrant (was the backpack abandoned?)	He retained a reasonable expectation of privacy despite backpack being thrown over fence	Backpack was voluntarily abandoned (dry on wet ground, no one claimed it), so no warrant required	Court held the backpack was abandoned; officers could retrieve and search without a warrant
Whether duration/scope of detention exceeded Terry limits	Brief handcuffing amounted to an arrest and exceeded permissible Terry scope	Detention was brief (5–10 minutes) and reasonably tailored to investigation and safety concerns	Court held duration and scope were reasonable; no Miranda violation

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation)
Terry v. Ohio, 392 U.S. 1 (1968) (permitting brief investigative stops based on reasonable, articulable suspicion)
United States v. Sharpe, 470 U.S. 675 (1985) (no rigid time limit on Terry stops; review under reasonableness and investigatory purpose)
State v. Gatewood, 163 Wn.2d 534 (2008) (discussing warrant requirement and Terry exception in Washington)
State v. Evans, 159 Wn.2d 402 (2007) (police may search voluntarily abandoned property without warrant)