State v. Lewis, 333 Conn. 543

At ~4:16–4:19 a.m. a 911 caller reported a domestic assault: a black male (identified as "O") had broken a window and choked her; she thought he was still nearby and described him as wearing black clothing and a fitted orange/grey hat.
Officer Milton DeJesus, patrolling nearby, saw Lewis about one minute after dispatch standing alone in a poorly lit parking lot ~1 minute's walk from the reported scene, wearing dark clothing and talking on a cell phone in heavy rain.
DeJesus stopped his cruiser ~15 feet away, asked Lewis his name from the vehicle, then exited and approached nonconfrontationally; Lewis mumbled incoherently, swayed, and appeared intoxicated or impaired.
DeJesus began a patdown for weapons, felt a firearm in Lewis’s waistband, a struggle ensued, backup/canine arrived, and Lewis was arrested; it was later determined he was not the assailant.
Lewis moved to suppress the gun, arguing the encounter was an unlawful seizure and frisk; trial court denied suppression, Appellate Court affirmed, and the Connecticut Supreme Court granted certification and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) When did a "seizure" occur?	State: No seizure until officer physically touched Lewis; prior questions/maneuvers were noncoercive.	Lewis: He was seized when cruiser stopped near him or when officer exited and approached.	Held: No seizure under federal or state constitutions until the officer touched Lewis; the stop/approach and questions were not objectively coercive.
2) Was there reasonable and articulable suspicion to stop/detain Lewis?	State: Yes — close temporal/geographic proximity to a violent domestic assault, general clothing match (obscured by rain/dark), lone presence, time of day, and evasive/mumbled behavior.	Lewis: No — discrepancies in clothing/name and collective-knowledge issues negate suspicion.	Held: Yes — under the totality of the circumstances (including obscuring weather, proximity in time/place, and conduct) the officer had reasonable suspicion to detain.
3) Was the Terry patdown for weapons lawful?	State: Yes — the reported crime involved violent domestic violence (choking), increasing the risk the suspect might be armed; proximity and behavior supported frisk.	Lewis: No — victim said suspect had no weapon; officer’s testimony that he "pats everybody down" shows improper practice.	Held: Yes — a choking/domestic-violence report plus the defendant’s proximity and circumstances gave reasonable suspicion he might be armed; the victim’s lack-of-knowledge about weapons did not negate the risk.

Terry v. Ohio, 392 U.S. 1 (Terry stop/patdown doctrine)
State v. Edmonds, 323 Conn. 34 (limits on relying on "high crime area" shorthand; factors for seizure analysis)
State v. Burroughs, 288 Conn. 836 (consent vs. seizure; questioning and vehicle placement considerations)
State v. Kyles, 221 Conn. 643 (description-matching and reasonableness of suspect stops)
State v. Butler, 296 Conn. 62 (collective knowledge doctrine applied to reasonable suspicion)
State v. Wilkins, 240 Conn. 489 (frisk law: officer may patdown if reasonably believes detainee might be armed)
Immigration & Naturalization Serv. v. Delgado, 466 U.S. 210 (questioning does not by itself constitute seizure)
California v. Hodari D., 499 U.S. 621 (physical force/submission test under federal law)
State v. Oquendo, 223 Conn. 635 (state seizure test and factors to evaluate coercion)