State Of Washington v. Sarah Jean Sewares, 49242-3

A confidential informant (CI) with a reliable track record told police Christopher Neff would deliver heroin to a specific motel; officers verified the tip and watched Neff arrive.
Neff exited a vehicle with two women, Sarah Sewares and Jazmine Hammond; all three walked to the motel room identified by the CI. Hammond had a backpack; Sewares carried a purse.
Officers detained and handcuffed Neff, Sewares, and Hammond outside the motel room as part of the drug delivery investigation; Sewares was perceived as an accomplice to Neff.
Detective Withrow asked Sewares whether she possessed any controlled substances; Sewares admitted she had methamphetamine in her purse.
Withrow looked into Sewares’s open purse, saw an open pill bottle containing methamphetamine, and seized it. Sewares was charged with possession and moved to suppress the evidence.
The trial court denied the suppression motion, found the stop lawful under Terry, convicted Sewares following a bench trial, and Sewares appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the detention a lawful Terry stop?	Sewares: detention was an unlawful seizure; insufficient specific and articulable facts.	State: CI tip, officers’ verification, Neff’s arrival with Sewares who entered target room — provided reasonable suspicion.	Court: Stop was a lawful Terry stop given CI’s reliability and corroboration.
Did Withrow exceed the scope of the Terry stop by asking about controlled substances?	Sewares: questioning and purse inspection exceeded investigatory scope.	State: question was reasonably related to investigating suspected drug delivery and permissible to confirm/dispel suspicion.	Court: Asking if Sewares had controlled substances was within Terry scope; seizure lawful.
Was the seized methamphetamine admissible under plain view/consent from admission?	Sewares: seizure flowed from unlawful detention/questioning, so evidence must be suppressed.	State: Sewares voluntarily admitted possession and officer observed contraband in open purse; seizure lawful.	Court: Evidence admissible; suppression properly denied.
Did officers need probable cause or a warrant before the search/seizure?	Sewares: search of purse required probable cause/arrest.	State: initial detainment was investigatory; officers’ follow-up questioning and observation of contraband fell within Terry limits.	Court: No warrant/probable cause required at that stage; observation/seizure were lawful.

Terry v. Ohio, 392 U.S. 1 (1968) (articulates standards for investigative stops)
State v. Doughty, 170 Wn.2d 57 (2010) (Terry stop requires well-founded suspicion)
State v. Acrey, 148 Wn.2d 738 (2003) (scope/duration of Terry stop; questions to confirm or dispel suspicion)
State v. O'Neill, 148 Wn.2d 564 (2003) (unchallenged findings are verities on appeal)
State v. Garvin, 166 Wn.2d 242 (2009) (warrantless searches presumptively invalid; enumerates exceptions)
State v. Hendrickson, 129 Wn.2d 61 (1996) (State bears burden to show warrant or applicable exception)
State v. Flores, 186 Wn.2d 506 (2016) (intrusive detention exceeding investigatory stop transforms into arrest requiring probable cause)