State v. Patrick, 1608021083

Background

On August 28, 2016 Dover police encountered Kelly L. Patrick seated in a vehicle parked in an alley that blocked a garage and sat in front of "no parking" signs in an area the officers described as a high‑crime, open‑air drug market.
A probation officer (who did not testify) observed a male briefly approach the car then quickly leave by cutting through a yard; the probation officer also saw Patrick duck down in the driver’s seat.
Two police vehicles (one marked, one unmarked) entered the alley and stopped near the car; officers then approached.
A man was working under the car’s hood and identified himself as a mechanic; he appeared nervous.
Plainly visible on a front seat were a digital scale, loose cash, and numerous plastic baggies.
After identification checks, officers learned Patrick had two outstanding capiases for missed court appearances. Patrick was arrested for drug dealing, three weapon offenses, and possession of paraphernalia; she moved to suppress evidence seized from the vehicle.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police conduct amounted to a seizure (Terry stop) when their vehicles entered the alley and stopped near Patrick’s car	Patrick: the cars blocked her egress and a reasonable person would not feel free to leave, so a seizure occurred at that moment	State: initial contact was justified by circumstances; even if a seizure occurred, officers had grounds to detain	Court: need not decide precisely when seizure occurred; at the earliest relevant point officers had reasonable suspicion to justify detention
Whether officers had reasonable, articulable suspicion of criminal activity to justify the stop	Patrick: the State relied largely on hearsay (Probation Officer Porter) and thus failed to meet its burden	State: corroborating, first‑hand observations (high‑crime area, illegal parking, observed ducking, plain view items) supplied reasonable suspicion	Court: totality of circumstances (area, parking/trespass, furtive movements, plain view items, nervous mechanic) provided reasonable, articulable suspicion; detention lawful
Whether hearsay alone can support detention	Patrick: Hopkins requires more than hearsay to support warrantless seizure	State: officer offered corroborating first‑hand observations sufficient for minimal Terry standard	Court: Hopkins distinguishable; first‑hand corroboration rendered hearsay acceptable for reasonable suspicion analysis
Whether Patrick’s outstanding capiases cure any alleged initial illegality or require suppression analysis	Patrick: capiases discovered only after ID; argues initial seizure unlawful	State: outstanding capias justified arrest independently; inevitable discovery/search‑incident arguments asserted but not necessary	Court: noted capiases would independently justify arrest but declined to resolve whether capias cured any prior taint or to decide inevitable discovery; denied suppression on other grounds

Key Cases Cited

Hunter v. State, 783 A.2d 558 (Del. 2001) (burden on State to justify warrantless search and seizure)
Jones v. State, 745 A.2d 856 (Del. 1999) (Delaware standard for seizure: would a reasonable person feel free to ignore officer and walk away)
Turner v. State, 957 A.2d 565 (Del. 2008) (trial judge as factfinder at suppression hearings and assesses credibility)
Hall v. State, 981 A.2d 1106 (Del. 2009) (blocking a vehicle and ordering occupant’s compliance can constitute a seizure)
Moreuso v. Baca, 431 F.3d 633 (9th Cir. 2005) (after‑the‑fact discovery of a warrant does not necessarily retroactively justify an earlier suspicionless seizure)