Woodson v. State, 960 N.E.2d 224

Woodson was convicted of two counts of Fraud (Class D felonies) and appeals, challenging admission of seized DVDs.
Officer Cooper stopped Woodson in a high-crime area after Woodson exited a car and approached on a bicycle with a backpack.
Woodson consented to a backpack search, yielding 34 DVDs with handwritten titles.
The DVDs were not manufactured by the studios and matched titles (e.g., Green Hornet, Sanctum).
Woodson moved to suppress the DVDs as fruits of an unlawful search; the trial court denied the motion and he was convicted.
On appeal, the court reversed, finding the stop unconstitutional and the DVDs improperly admitted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the DVDs should have been suppressed as the fruit of an unlawful search	Woodson	Woodson	Conviction reversed; suppression required.

United States v. Arvizu, 534 U.S. 266 (2002) (reasonable suspicion under totality of the circumstances)
Terry v. Ohio, 392 U.S. 1 (1968) (establishes stop-and-frisk standard for reasonable suspicion)
United States v. Cortez, 449 U.S. 411 (1981) (totality of the circumstances standard for stops)
Calmes v. State, 894 N.E.2d 199 (Ind. Ct. App. 2008) (consensual encounter test in Indiana)
Crabtree v. State, 762 N.E.2d 241 (Ind. Ct. App. 2002) (factors indicating a person is not free to leave)
Boston v. State, 947 N.E.2d 436 (Ind. Ct. App. 2011) (standard for reviewing admissibility of evidence)
Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (probative value standard for evidentiary rulings)
Widduck v. State, 861 N.E.2d 1267 (Ind. Ct. App. 2007) (consideration of uncontested evidence in review)
Harper v. State, 922 N.E.2d 75 (Ind. Ct. App. 2010) (de novo review of constitutional claims)
Wilson v. State, 670 N.E.2d 27 (Ind. Ct. App. 1996) (reasonableness of suspicion in drug-transactions context)