State v. Shoulders, 962 N.E.2d 847

Shoulders was charged with drug trafficking, receiving stolen property (a gun), and possession of criminal tools, with forfeiture and firearm specifications.
Prior to trial, Shoulders moved to suppress; an evidentiary hearing was held with Detective Valentino and Sergeant Pillow testifying.
Officers, in unmarked cars, observed Moore at a car wash; they intended to question Moore about a threat involving a Browns player and weapons.
Shoulders, an employee at the car wash, allegedly ran when officers drew their weapons; he was detained, frisked, and marijuana, phones, cash, and a pistol were found.
The pistol was later found to be stolen; other car wash patrons testified Shoulders did not run, contradicting officers' account.
The trial court denied the suppression motion; at trial, Counts 2 and 3 were dismissed; Shoulders was convicted of drug trafficking with firearm specification and forfeiture.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly denied suppression	Shoulders: unlawful stop and search	Shoulders: no reasonable suspicion; stop invalid	Appeal sustained; suppression motion granted; remanded

Wardlow, 528 U.S. 119 (2000) (flight alone not per se; totality of circumstances governs reasonable suspicion)
Ybarra v. Illinois, 444 U.S. 85 (1979) (mere propinquity to others suspected of crime insufficient for search)
Maryland v. Pringle, 540 U.S. 366 (2003) (personalized suspicion required; guilt must be particularized)
Terry v. Ohio, 392 U.S. 1 (1968) (brief, warrantless stop permissible with reasonable suspicion)