Turley v. Commonwealth, 399 S.W.3d 412

Appellant Stewart Turley was stopped for speeding and an improperly illuminated plate on a rural Muhlenberg County road.
During the stop, Turley’s two passengers remained in the truck while Turley underwent a field sobriety test and provided his documents, which were returned after the stop’s initial conclusions.
Knight then re-approached the vehicle and detained the three occupants under a Terry detention to question the passengers and run warrants checks.
A small wooden box near the center console drew Knight’s attention; Turley opened the box under duress, and a bag of marijuana fell out, leading to Turley’s arrest.
A subsequent vehicle search uncovered methamphetamine, pills, two handguns, and cash; Turley was indicted on first-degree possession of a controlled substance, possession of marijuana, and as a second-degree persistent felony offender, with a collective twenty-year sentence.
The Muhlenberg Circuit Court denied Turley’s pretrial motion to suppress the evidence as products of an illegal seizure, and Turley was tried and convicted on the caps charged, prompting appellate review of suppression issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the continued detention after the stop’s purpose ended was lawful	Turley’s suppression brief argues extended detention violated the Fourth Amendment	Commonwealth contends the later Terry detention of passengers legitimized continued encounter	Custody extended beyond the stop’s purpose; suppression required
Whether Turley remained in custody when Knight told him to “have a good night” and re-approached the truck	Turley remained in custody; control persisted after initial stop	The encounter became consensual after returning documents	Turley remained in custody; subsequent evidence suppressible
Whether the box seizure was justified by exigent circumstances or police-created exigency	Exigent circumstances justified seizure under public safety exception	Knight created the exigency by extending the stop and demanding contents of the box	Exigency not justified; suppression appropriate; Knight’s conduct invalidated the seizure
Whether the evidence flow from the unlawful detention tainted subsequent searches	Evidence recovered after unlawful detention is fruit of the poisonous tree		Suppression affirmed; all post-stop evidence suppressed

Florida v. Royer, 460 U.S. 491 (1983) (investigative detention must be temporary and related to stop purposes)
United States v. Hunnicutt, 135 F.3d 1345 (10th Cir. 1998) (two-step exception: unrelated questioning or consensual encounter after stop)
United States v. Place, 462 U.S. 696 (1983) (limited seizures; protective reasons for temporary seizure of box/container)
Kentucky v. King, 131 S. Ct. 1849 (2011) (police-created exigency cannot justify unlawful conduct; King governs exigency analysis)
Epps v. Commonwealth, 295 S.W.3d 807 (Ky. 2010) (illegally extended detentions yield suppression of contraband evidence)
United States v. Ross, 456 U.S. 798 (1982) (automobile exception; probable cause to search containers within a vehicle)
Delaware v. Prouse, 440 U.S. 648 (1979) (stopping vehicle for license/registration must be reasonable absent suspicion)
Owens v. Commonwealth, 291 S.W.3d 704 (Ky. 2009) (passenger detention warrant-check context distinguished; not controlling here)
Ward v. Commonwealth, 345 S.W.3d 249 (Ky.App. 2011) (rejected notion that passengers may routinely be detained for warrant checks in a routine stop)