State v. Thompson, 93 So. 3d 553

Thompson was charged with possession with intent to distribute cocaine after police, executing narcotics warrants at the Levingston Motel, recovered cocaine from his truck following his consent to search.
Thompson moved to suppress, contending the consent to search originated from an illegal detention; two suppression hearings were held in April 2009, with surveillance video later introduced.
The Special Response Team executed warrants for Rooms 31 and 37; Thompson was detained in the motel parking area, questioned, Mirandized, and his truck was searched after he admitted weapon and drugs.
The trial court denied the motion to suppress, finding the consent voluntary and the initial detention lawful, without determining whether the detention was illegal.
The Court of Appeal reversed, holding the initial detention illegal and the consent tainted, and remanded for further proceedings; the state sought Supreme Court review.
The Supreme Court reversed the Court of Appeal, reinstated the trial court’s denial of the motion to suppress, and remanded for review of remaining issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the initial detention a valid investigatory stop?	Thompson	Thompson	Yes; initial detention lawful.
Did continued detention and questioning after the pat-down taint the subsequent consent to search?	Thompson	Thompson	No; consent attenuated and voluntary.
Was the trial court's denial of the motion to suppress an abuse of discretion given the recorded and testimonial evidence?	Thompson	Thompson	No; no abuse; suppression reversed and remanded.

State v. Wells, 45 So.3d 577 (La. 2010) (burden on state to prove admissibility; defer to trial court findings)
State v. Dobard, 824 So.2d 1127 (La. 2002) (threshold test for investigatory stops under Fourth Amendment/La. Const.)
Summers, 452 U.S. 692 (U.S. 1981) (hot pursuit of safety concerns in narcotics warrant context; high crime area)
State v. Mena, 544 U.S. 93 (U.S. 2005) (limits on police questions during lawful detention; post-stop inquiries permitted)
State v. Porche, 943 So.2d 335 (La. 2006) (handcuffing during investigatory stops; appropriate restraint under Terry)
State v. Palmer, 14 So.3d 304 (La. 2009) (factors for evaluating use of handcuffs and continuance of detention)
Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (search incident to arrest; probable cause to search vehicle after arrest)
Brendlin v. California, 551 U.S. 249 (U.S. 2007) (passenger seizure and scope of stop)