State v. Simpson, 1608013425

Defendant Tyrell Simpson arrived at Wilmington Hospital in a red Pontiac Grand Prix with broken windows and bullet holes; he was the sole occupant and reported he had been shot, with visible blood on his clothing.
Constable Richardson observed these facts, had prior experience encountering shooting victims arriving at the hospital, and secured the vehicle pending Wilmington Police investigation.
The vehicle was detained and later searched pursuant to a warrant; evidence from the vehicle is the subject of suppression efforts.
Defendant moved to suppress evidence from the vehicle search and later filed a Motion for Reargument after the court’s initial July 20, 2017 opinion; an amended motion produced the correct search warrant for review.
The court reconsidered whether the vehicle detention and Defendant’s detention were lawful and whether the search warrant (as amended) established probable cause for searching the vehicle.

Issue	State's Argument	Simpson's Argument	Held
Lawfulness of vehicle detention	Constable had reasonable, articulable suspicion the vehicle was involved in a shooting based on objective facts and officer experience	Detention was improper and premised on a supposed "hospital policy" exception to the Fourth Amendment	Court: Detention lawful — reasonable suspicion supported by totality of circumstances; no "hospital policy" exception relied upon
Arrest vs. investigatory detention of Simpson	Encounter was an investigatory detention supported by §§ 1902(a), 1910 and Harris, not an arrest	Simpson contended he was arrested rather than detained	Court: Encounter was a temporary detention, not an arrest; denial of reargument on this point
Search warrant validity for vehicle	Warrant described the vehicle and sought ballistic evidence tied to a shooting; magistrate had substantial basis for probable cause	Warrant lacked indication Simpson committed an offense and was "fruit of the poisonous tree" from prior seizure	Court: Warrant facially supported probable cause for vehicle search; amended motion to suppress denied
Whether vehicle search was tainted by initial seizure	State argued detention was lawful so search was not tainted	Simpson argued search was fruit of illegal seizure and evidence should be suppressed	Court: Because detention was lawful, and warrant valid, suppression denied (reargument granted only to review correct warrant)

Harris v. State, 622 A.2d 1095 (Del. 1993) (investigatory stop authority and preventing flight of suspects near crime scenes)
Purnell v. State, 832 A.2d 714 (Del. 2003) (totality-of-circumstances review from the viewpoint of a reasonable trained officer)
State v. Holden, 60 A.3d 1110 (Del. 2013) (reviewing court must ensure magistrate had substantial basis for probable cause; deferential Gates review)
Illinois v. Gates, 426 U.S. 213 (1983) (established totality-of-the-circumstances test for probable cause in warrant affidavits)