State v. Malachi, 264 N.C. App. 233

Shortly after midnight, an anonymous 911 caller reported at a gas station that a Black male in a red shirt and black pants had placed a handgun in his waistband.
Officer Ethan Clark (uniformed, marked car) and Officer Jason Van Aken arrived; Clark saw a person matching the description (Malachi).
As Clark exited his car and made eye contact, Malachi “bladed,” turned his body away, and began to walk away; Clark and Van Aken grabbed his arms and detained him.
Clark placed Malachi in handcuffs, Van Aken frisked him, and a revolver was recovered from Malachi’s waistband; Malachi was then arrested.
Malachi moved to suppress the gun evidence as the product of an unconstitutional stop/frisk; the motion was denied, no trial objection was made, and Malachi was convicted of possession of a firearm by a felon (and later sentenced as an habitual felon). On appeal he raised plain error review of the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless stop and frisk violated the Fourth Amendment such that admitting the gun was plain error	The State: officers had reasonable, articulable suspicion under the totality of circumstances (anonymous tip corroborated by identification, Malachi’s blading/flight, officers’ training, and failure to disclose being armed) to stop and frisk for officer safety	Malachi: anonymous tip identifying location/appearance alone cannot supply reasonable suspicion for a Terry stop and frisk; admission of the gun was therefore unconstitutional and prejudicial	Court: No plain error. Under Terry and applying totality of circumstances (tip plus corroborating conduct — blading, movement away, struggle, failure to disclose), officers had reasonable suspicion both that criminal activity may be afoot and that Malachi was armed and dangerous, so frisk and admission of the gun were lawful.

Terry v. Ohio, 392 U.S. 1 (1968) (framework permitting stop-and-frisk on reasonable, articulable suspicion for officer safety)
Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip giving only description/location is insufficient alone to justify a frisk)
State v. Rinck, 303 N.C. 551 (1981) (if detention shows indicia of criminal activity and suggests the detainee may be armed, officer may frisk for protection)
United States v. Robinson, 846 F.3d 694 (4th Cir. 2017) (officer may frisk when reasonably suspecting the stopped person is armed; legality of possession does not negate officer safety concern)