State Of Washington v. Tachelle S. Thomas
73912-3
Wash. Ct. App.Oct 3, 2016Background
- Officers Bennett and Stewart investigated a reported stolen GMC van parked directly in front of a residence known for prior stolen-vehicle and criminal activity.
- The van was filled with property except the driver and front passenger seats; motorcycle helmets, gloves, and men’s and women’s clothing were visible.
- Court paperwork found in the van bore the name "Shyla Gypin."
- Thomas and a woman (later identified as Shyla Gypin) emerged from the residence; Thomas was wearing a motorcycle jacket.
- Officers asked the woman her name and then asked Thomas for identification; dispatch confirmed outstanding warrants and Thomas was arrested.
- A search incident to arrest produced plastic bags later confirmed to contain methamphetamine; Thomas moved to suppress, claiming the stop was unlawful.
Issues
| Issue | Plaintiff's Argument (Thomas) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to briefly detain Thomas under Terry | The facts observed (motorcycle jacket; presence with a woman; being at the residence) were innocuous and insufficient for reasonable suspicion | Officers had specific, articulable facts (stolen van parked at the residence, empty front seats, matching motorcycle gear, paperwork with Gypin's name, officers’ familiarity with area and gear) supporting a Terry stop | Trial court findings (unchallenged) supported reasonable suspicion; suppression denied |
Key Cases Cited
- State v. Fuentes, 183 Wn.2d 149 (discusses Terry-stop reasonable suspicion standard and review of suppression rulings)
- Terry v. Ohio, 392 U.S. 1 (establishes investigative stop (Terry) doctrine)
- State v. Kennedy, 107 Wn.2d 1 (definition of reasonable suspicion as substantial possibility of criminal conduct)
- State v. Tijerina, 61 Wn. App. 626 (holding that innocuous facts cannot alone support reasonable suspicion)
- Mueller v. Wells, 185 Wn.2d 1 (unchallenged factual findings are verities on appeal)
