State v. Robinson, 396 S.C. 577

Robinson was convicted of possession with intent to distribute crack cocaine, possession within one-half mile of a public park, unlawful carrying of a pistol, possession of marijuana, and resisting arrest, resulting in a life sentence.
Police surveilled Hall Street Apartments due to anonymous complaints; Ervin observed conduct consistent with drug transactions and called for backup.
Officers smelled marijuana on the porch; Robinson had a pistol visible in his jacket; a struggle ensued and Robinson fled as officers attempted a Terry stop and search.
Robinson was placed in handcuffs after a pursuit; Schettler conducted a jacket search revealing a pistol, marijuana, and crack cocaine.
Robinson moved to suppress the seized items; the circuit court denied the motion; marijuana later entered into evidence as trial strategy by Robinson.
Commander Marvin Brown was offered as an expert on crack cocaine packaging, pricing, and user/dealer behavior; the court qualified him as an expert over Robinson’s objection; Robinson was convicted and sentenced to life under statute 17-25-45.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the crack cocaine and related items were unlawfully seized	Robinson argues the search violated Fourth Amendment rights.	State contends there was reasonable suspicion and no legitimate privacy expectation.	No Fourth Amendment violation; reasonable suspicion supported the stop and frisk.
Whether Commander Brown was properly qualified as an expert	Robinson contends Brown lacked Rule 702 qualification.	State asserts Brown's experience qualifies him as an expert.	Brown properly qualified as an expert; his testimony allowed to aid the jury.

State v. Missouri, 361 S.C. 107 (2004) (requires legitimate expectation of privacy for Fourth Amendment claims)
Oliver v. United States, 466 U.S. 170 (1984) (definition of legitimate expectations of privacy)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion allows brief investigative stop)
State v. Banda, 371 S.C. 245 (2006) (nexus between drugs and guns justifies frisk for weapons with reasonable suspicion)
State v. Foster, 269 S.C. 373 (1977) (consent to see identification is not a seizure; encounter may be consensual)
State v. Flowers, 360 S.C. 1 (2004) (overarching privacy expectations depend on relationship to property)
State v. Corley, 383 S.C. 232 (Ct.App.2009) (totality of circumstances in assessing reasonable suspicion)
State v. Blue? Commander, 384 S.C. 66 (Ct.App.2009) (expert testimony weight limitations; not automatically controlling weight)
State v. Taylor, 388 S.C. 101 (Ct.App.2010) (reasonableness of suspicion and investigatory stops)
State v. Henry, 329 S.C. 266 (Ct.App.1997) (experience can qualify as expertise for admissibility)