Williams v. Commonwealth, 364 S.W.3d 65

Nine individuals, including Williams, stood in front of a vacant house; some openly engaged in marijuana use and carried handguns; police observed the group for 10–15 minutes before approaching.
An officer frisked members and discovered two handguns on others, then ordered the group to lie on the ground and respond about weapons.
Williams, on crutches, was seen with a bulge in his back when down on the ground, which proved to be a handgun tucked in his waistband.
Williams moved for suppression, arguing the stop and patdown were unlawful as not reasonably suspicious of him personally.
The trial court denied suppression; Williams pled guilty conditionally, preserving the right to appeal the suppression ruling; on appeal, the Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was justified by reasonable suspicion of Williams personally	Williams argues no individualized suspicion.	Commonwealth contends the group’s behavior created suspicion for the whole group, including Williams.	Yes; the stop was justified by individualized reasonable suspicion within the group context.
Whether the nine-person group constituted a distinct unit for analysis	Williams contends no distinct group existed to tailor suspicion to him.	Commonwealth argues the group functioned as a unit with shared behavior.	Yes; substantial evidence supported a finding of a distinct group.
Whether Ybarra governs this case and distinguishes it	Ybarra requires suspicion directed at the person; Williams asserts Ybarra controls.	Group context distinguishes this case from Ybarra.	No; Williams’s group context justifies the stop.
Whether presence in a high-crime area or association with criminals alone justifies a stop	Williams argues mere presence/association is insufficient.	Group behavior and drug activity plus weapons justify a stop.	Presence/association alone is insufficient, but here group conduct supported reasonable suspicion.

Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable-suspicion rule for stops and frisk for weapons when armed and dangerous)
Ybarra v. Illinois, 444 U.S. 85 (1979) (limits frisk when not directed at the individual searched)
United States v. Cortez, 449 U.S. 411 (1981) (totality-of-the-circumstances approach to stops)
Adams v. Williams, 407 U.S. 143 (1972) (police may conduct a protective frisk when armed and suspicious circumstances exist)
Brown v. Texas, 443 U.S. 47 (1979) (mere presence in a high-crime area not enough to justify a stop)
Ybarra, 444 U.S. at 91, Ybarra v. Illinois, 444 U.S. 85 (1979) (illustrates limits of on-premises frisk)
Commonwealth v. Banks, 68 S.W.3d 347 (Ky. 2001) (guides consideration of factors in suspicion analysis)
Strange v. Commonwealth, 269 S.W.3d 847 (Ky. 2008) (ky interpretation of stop-and-search standards)