State v. Anderson, 783 S.E.2d 51

Police obtained a no‑knock warrant for a house on Dobbs Street based on suspected drug activity; the warrant did not include a nearby footpath used by runners to ferry drugs to Sullivan Street.
Greenville SWAT officers were instructed to secure and detain persons found on the footpath during the raid because it was known to be used for drug transport.
Detectives Hyatt and Rhinehart encountered Donald Anderson walking on the footpath; after seeing officers, Anderson veered off the path toward a yard.
Detective Hyatt drew his weapon, ordered Anderson to the ground, handcuffed him, and performed a pat‑down, discovering a bag of crack cocaine in Anderson’s pocket.
Anderson moved to suppress the evidence, arguing the stop was outside the warrant’s scope and, alternatively, that there was no reasonable suspicion for a Terry stop or for believing he was armed; the trial court denied suppression and convicted him; the court of appeals affirmed.
The South Carolina Supreme Court granted certiorari and reversed, holding the officers lacked reasonable suspicion to detain Anderson and thus the seizure was unconstitutional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion to detain Anderson for an investigatory stop	Anderson: No particularized suspicion; mere presence near a search and stepping off the path was innocuous	State: Presence in high‑crime area near a search and evasive movement justified detention	Held: No — totality of circumstances did not supply particularized, objective suspicion to justify the stop
Whether the pat‑down was lawful because officer reasonably believed Anderson was armed	Anderson: No lawful stop, so pat‑down unlawful; no facts showed he was armed	State: Officer safety concerns and evasive conduct supported belief he was armed	Held: Not reached on merits because initial seizure unconstitutional; court declined to address pat‑down separately

Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for brief investigative stops based on reasonable suspicion)
Mapp v. Ohio, 367 U.S. 643 (1961) (exclusionary rule for evidence obtained in violation of the Fourth Amendment)
Minnesota v. Dickerson, 508 U.S. 366 (1993) (limits on pat‑down searches and seizure of contraband detected during protective frisks)
United States v. Cortez, 449 U.S. 411 (1981) (totality‑of‑circumstances test for reasonable suspicion)
United States v. Arvizu, 534 U.S. 266 (2002) (emphasizes reviewing the whole picture when assessing reasonable suspicion)
State v. Taylor, 401 S.C. 104, 736 S.E.2d 663 (2013) (South Carolina case discussing evasive conduct as a factor in reasonable suspicion analysis)