State v. Holt
206 Md. App. 539
Md. Ct. Spec. App.2012Background
- Holt was stopped July 13, 2011 after detectives surveilled a known drug dealer, Blue, who had previously supplied heroin to Townsend in June 2011.
- Blue and Holt briefly met in a public location at Lake Montebello; Blue left with a Rubbermaid container and Holt drove away in Holt’s Jeep.
- Detectives followed Holt, activated emergency lights, and a confrontation ensued in which Holt allegedly pointed a handgun at Detective McShane and drove toward him.
- The circuit court found no reasonable suspicion to justify the stop and suppressed firearm-related observations, while allowing some vehicle-based evidence to be admitted.
- The State appealed, arguing the stop was supported by reasonable suspicion and that evidence of the firearm and related conduct should not be suppressed.
- On appeal, the court held the stop was supported by reasonable suspicion and that the taint from the stop was attenuated by Holt’s subsequent actions, allowing admission of related testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion to stop Holt? | Holt | Holt | Yes; stop supported by articulable suspicion |
| Does a subsequent distinct crime purge the taint of an unlawful stop? | State | Holt | Yes; taint attenuated, subsequent crimes admissible |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (U.S. Supreme Court (1968)) (established reasonable suspicion standard for brief stops)
- Mapp v. Ohio, 367 U.S. 643 (U.S. Supreme Court (1961)) (exclusionary rule applicable to states)
- Whren v. United States, 517 U.S. 806 (U.S. Supreme Court (1996)) (reaffirmed focus on objective reasonable suspicion, not police intent)
- Illinois v. Wardlow, 528 U.S. 119 (U.S. Supreme Court (2000)) (nervous, evasive behavior as a factor in reasonable suspicion)
- Ar vizu, 534 U.S. 266 (U.S. Supreme Court (2002)) (totality of circumstances standard for suspicion)