State v. Chandler
132 A.3d 133
| Del. Super. Ct. | 2015Background
- On May 7, 2014, Trooper Radcliffe stopped Michael Chandler for speeding (48 mph in a 25 mph zone) on DE Route 1; Chandler produced valid license and a rental agreement in his name.
- During the stop Chandler exhibited visible nervousness; Radcliffe ran computer checks, discovered an alias and an extensive criminal history, and called for backup.
- After backup arrived, officers conducted a weapons pat-down (no weapons found), continued questioning about the alias and travel, and sought consent to search the vehicle; Chandler initially refused consent.
- Troopers then restricted Chandler near the patrol vehicle, called for a narcotics K9, and placed a tire stop after expressing concern he might flee.
- About 40 minutes after the initial stop, the K9 alerted and officers searched the vehicle, discovering heroin and cocaine in the trunk.
- Chandler moved to suppress all evidence from the warrantless search, arguing the stop was unlawfully extended beyond the speeding investigation; the State argued reasonable suspicion justified waiting for the K9.
Issues
| Issue | Chandler's Argument | State's Argument | Held |
|---|---|---|---|
| Whether officers lawfully expanded a traffic stop into a prolonged investigative detention | Stop should have ended after valid credentials were verified; further detention violated Fourth Amendment | Officers had reasonable, articulable suspicion (nervousness, alias, criminal history, rental car, inconsistent answers, multiple phones) to extend the stop and wait for K9 | Court: Extended detention was unlawful; suppression granted |
| Whether pat-down for weapons was justified | Pat-down exceeded scope because stop was for speeding and safety concern was minimal | Pat-down justified by extreme nervousness, alias, criminal history and officer safety concerns | Court: Pat-down was justified (reasonable suspicion of being armed) |
| Whether facts known before the extended detention supplied reasonable suspicion to detain further | Many allegedly suspicious facts (inconsistencies, multiple phones) were developed after the detention began and cannot justify it | Those facts supported reasonable suspicion to prolong detention | Court: Post-seizure observations cannot retroactively justify the prior seizure; absence of pre-seizure indicators meant no reasonable suspicion |
| Whether combination of nervousness, alias, criminal history, rental car sufficed for reasonable suspicion | These factors alone are insufficient to support prolonged investigative detention | In combination they reasonably suggested drug trafficking and justified K9 wait | Court: Combination of those innocent factors (as known pre-extension) did not amount to reasonable suspicion under totality of circumstances |
Key Cases Cited
- Hunter v. State, 783 A.2d 558 (Del. 2001) (State bears burden on motion to suppress)
- Caldwell v. State, 780 A.2d 1037 (Del. 2001) (traffic-stop scope/duration and limits on unrelated investigation)
- Loper v. State, 8 A.3d 1169 (Del. 2010) (officer safety may justify certain measures during stop)
- Arizona v. Johnson, 555 U.S. 323 (2009) (unrelated questioning permitted if it does not measurably extend stop)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (traffic stop is a seizure)
- Pierce v. State, 19 A.3d 302 (Del. 2011) (context matters for whether asking about contraband constitutes a second detention)
- Jones v. State, 745 A.2d 856 (Del. 1999) (post-seizure conduct cannot be used to create reasonable suspicion for an earlier seizure)
- Holden v. State, 23 A.3d 843 (Del. 2011) (pat-down standard; reasonable suspicion must be articulable)