State v. Kelly, 313 Conn. 1

Defendant Jeremy Kelly was stopped on Brown Street in Hartford during a police stop of his companion Burgos; officers believed Burgos matched a description of Gomez, who was the target of an outstanding probation violation warrant and possibly armed.
A confidential informant had indicated Gomez could possess a firearm; officers located Burgos and Kelly near 13-15 Brown Street and Burgos made a furtive movement, prompting pursuit.
Officer Rivera tackled Kelly after he tripped; during the pursuit, Rivera recovered a bag of cocaine from Kelly’s hand and seized another bag from his person.
Trial court denied the motion to suppress, holding the stop incident to Burgos’ detention was a lawful protective measure to ensure officer safety; the Appellate Court affirmed.
This certified appeal asks whether Connecticut’s state constitution permits detaining a suspect’s companion for safety when the suspect is lawfully detained and potentially armed, and whether the underlying factual findings support the detention.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police may briefly detain a suspect’s companion without individualized suspicion	Kelly argues such detention is unconstitutional under article I, §§ 7, 9	State argues a safety-related detention is reasonable	Yes; detention of the companion is permissible for officer safety
Whether the trial court’s factual findings support the companion’s detention	Evidence did not establish Gomez’s dangerousness or warrant specifics	Evidence supported belief Gomez was armed/dangerous	Yes; the articulation supported reasonable safety detention

Terry v. Ohio, 379 U.S. 1 (U.S. (1968)) (reasonable suspicion allows brief detentions for safety)
Brendlin v. California, 551 U.S. 249 (U.S. (2007)) (passenger detention related to stop of driver is permissible in certain contexts)
Michigan v. Summers, 452 U.S. 692 (U.S. (1981)) (detention of dwelling occupants incident to a search)
Maryland v. Wilson, 519 U.S. 408 (U.S. (1997)) (police may order passengers to exit during traffic stops)
Ybarra v. Illinois, 444 U.S. 85 (U.S. (1979)) (proximate presence alone is not enough for a stop without suspicion)
Arizona v. Johnson, 555 U.S. 323 (U.S. (2009)) (patdown allowed when suspect is armed; companion detention weighed for safety)
United States v. Navedo, 694 F.3d 463 (2d Cir. (2012)) (detention analyzed under Fourth Amendment balancing)
State v. Oquendo, 223 Conn. 653 (Conn. (1992)) (consensual encounter becomes seizure under state constitution based on police show of authority)
State v. Davis, 283 Conn. 280 (Conn. (2007)) (textual/precedent alignment with Fourth Amendment analysis)
State v. Kelly, 129 Conn. App. 109 (Conn. App. (2011)) (Appellate Court analysis of companion detention in similar context)