Tyrone Shelton v. State of Indiana
2015 Ind. App. LEXIS 118
| Ind. Ct. App. | 2015Background
- Shelton was serving a 20-year sentence via Community Corrections home detention and signed a contract consenting to warrantless searches of his person, residence, vehicle, and property.
- An anonymous Crime Stoppers tip stated Shelton had marijuana in his home and that it was stolen from a police car; the tip named Shelton and noted his house arrest status.
- Officer Flanagan (K-9 handler) corroborated nonpublic details about the stolen marijuana and contacted Community Corrections; Case Manager Ross verified Shelton’s home detention and agreed to a surprise inspection.
- K-9 Dixie alerted on a cooler in Shelton’s attached garage; officers found 428 grams of marijuana, 4.04 grams of cocaine, MDMA pills, a digital scale, and partial fingerprints linking Shelton to the bags.
- Shelton moved to suppress the evidence as seized in a warrantless search beyond his contract terms; the trial court denied the motion, a jury convicted on all counts (with one marijuana charge reduced to misdemeanor), and Shelton appealed the admission of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence from a warrantless search of Shelton’s home was admissible | State: search was reasonable because Shelton consented via Community Corrections contract and officers had reasonable suspicion based on the anonymous tip corroborated by nonpublic facts | Shelton: the search violated the Fourth Amendment and exceeded the scope of his contractual consent; the State lacked reasonable suspicion | Court affirmed: search reasonable under Fourth Amendment due to search condition plus sufficient reasonable suspicion from corroborated anonymous tip |
Key Cases Cited
- Knights v. United States, 534 U.S. 112 (2001) (probationary/search-condition standards: reasonable suspicion suffices for searches of persons under a search condition)
- Griffin v. Wisconsin, 483 U.S. 868 (1987) (special needs and diminished privacy interests justify warrantless searches of supervised offenders)
- Schlechty v. State, 926 N.E.2d 1 (Ind. 2010) (distinguishing general reasonableness of searches from the requirement of reasonable suspicion under conditional release)
- Clark v. State, 994 N.E.2d 252 (Ind. 2013) (admissibility review standard when defendant appeals denial of suppression after conviction)
- Alabama v. White, 496 U.S. 325 (1990) (anonymous-tip reliability and the need for police corroboration to supply reasonable suspicion)