State Of Washington v. Mahadi A. Shire, 73294-3

Background

On Oct. 1, 2013, Officers Escalante and Beatty observed Mahadi Shire sitting near a gas station drinking from a 24-oz can that officers believed to be beer.
Officers approached; Shire asked whether the contact was "about the beer," then ran across six lanes of traffic and was detained.
Shire gave a false name; officers checked the database, identified him by a facial scar, then ran his correct identity and discovered two outstanding arrest warrants.
Shire was arrested, read Miranda warnings, and a search incident to arrest produced crack cocaine found in his pocket.
Shire moved to suppress the cocaine, arguing the detention was unlawful and excessive; the trial court denied the motion and a jury convicted him of possession. The Court of Appeals affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had authority to detain Shire for a suspected civil infraction (open container/public consumption)	Shire argued officers lacked basis to detain him and Terry principles didn’t apply	State argued officers observed a civil infraction in their presence and RCW 7.80.050(2) authorized detention to issue a notice	Held: Officers had probable cause to believe Shire was committing a civil infraction and could detain him to identify him
Whether there was sufficient evidence that Shire was drinking alcohol	Shire challenged factual finding, citing conflicting testimony and lack of physical evidence	State relied on officers’ eyewitness testimony and Shire’s own question "about the beer"	Held: Substantial evidence supports finding he was drinking beer; credibility conflicts are for the trial court
Whether the length of detention (~30 minutes) was excessive	Shire argued detention was longer than reasonably necessary	State argued delay caused by Shire’s false identification and verification was reasonably necessary; arrest followed quickly after warrant confirmation	Held: Detention length was reasonable given Shire’s false ID and time needed to identify him; not excessive
Whether the cocaine should be suppressed as fruit of unlawful detention/search	Shire argued evidence flowed from unlawful detention	State argued cocaine was discovered during a lawful search incident to arrest on valid outstanding warrants	Held: Search was incident to a valid arrest after identification/warrant discovery; cocaine admissible

Key Cases Cited

Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for brief investigatory stops based on reasonable suspicion)
State v. Duncan, 146 Wn.2d 166 (2002) (Terry does not apply where officer investigates a civil infraction not committed in presence)
State v. Armenta, 134 Wn.2d 1 (1998) (articulable facts and reasonable suspicion standards for investigatory stops)
State v. O'Neill, 148 Wn.2d 564 (2003) (defining seizure under Washington Constitution)
State v. Garvin, 166 Wn.2d 242 (2009) (standards of review for suppression motion findings and conclusions)
State v. Camarillo, 115 Wn.2d 60 (1990) (trial court credibility determinations and factual findings reviewed for substantial evidence)
State v. Brock, 184 Wn.2d 148 (2015) (authority to search incident to arrest)
State v. Hill, 123 Wn.2d 641 (1994) (substantial evidence and scope of appellate review)
State v. Bonds, 174 Wn. App. 553 (2013) (unchallenged findings are verities on appeal)
State v. Caldera, 66 Wn. App. 548 (1992) (harmless erroneous factual findings that do not affect legal conclusions)