EADDY v. STATE
| Docket Number: | 2009-KA-02035-SCT Linked Case(s): 2009-KA-02035-SCT |
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| Supreme Court: | Opinion Link Opinion Date: 06-23-2011 Opinion Author: Chief Justice Waller Holding: Reversed and rendered. |
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| Additional Case Information: |
Topic: Possession with intent to distribute - Motion to suppress - Investigatory stop - Good-faith exception - M.R.A.P. 28 |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Possession with intent to distribute - Motion to suppress - Investigatory stop - Good-faith exception - M.R.A.P. 28 |
| Summary of the Facts: | Terrance Eaddy was convicted of possession with intent to distribute and sentenced to fifteen years. He appeals. |
| Summary of Opinion Analysis: | Eaddy argues that the court erred in denying his motion to suppress. To determine the reasonableness of a search and seizure, the court considers whether the officer's action was justified at its inception, and whether it was reasonably related in scope to the circumstances which justified the interference in the first place. Unless the State proves that a warrantless search comes within an exception, all evidence seized from the search is inadmissible. Eaddy argues that the trial court erred in not making findings on the informant’s reliability, and that information from an unnamed informant with undisclosed reliability does not establish reasonable suspicion for an investigatory stop. Police officers may detain a person for a brief, investigatory stop consistent with the Fourth Amendment when the officers have reasonable suspicion, grounded in specific and articulable facts, that allows the officers to conclude the suspect is wanted in connection with criminal behavior. Grounds for reasonable suspicion to make an investigatory stop generally come from two sources: either the officers’ personal observation or an informant's tip. But the scope of an investigatory stop is limited. The scope of a search or seizure must relate to the initial circumstances that called for police action. Thus, when police detention exceeds the scope of the stop, the stop becomes a “seizure,” and the State must show probable cause. Based on the evidence in the record, the trial court committed clear error in finding that the officers had reasonably relied on the arrest warrants in making the investigatory stop. Although Officer Edwards had personal knowledge of Wendell Barnes’s identity and both officers knew about his arrest warrants, the record does not reflect that either officer knew the description of Barnes’s vehicle before making the stop. Absent further independent investigation, Barnes’s arrest warrants did not provide reasonable grounds to justify a stop of the red Cadillac with Texas plates. Barnes’s warrants also did not provide reasonable grounds to justify a stop of Eaddy beyond what was necessary for Officer Edwards to clarify his identity. Officers Jefferson and Edwards acted, without independent investigation, on the caller’s vague description of Barnes’s vehicle, and the court made no findings regarding the reliability of the anonymous caller’s information. The State argues that the officers, although mistaken, initiated the investigatory stop on a good-faith belief that Wendell Barnes, the owner of the red Cadillac, would be driving the vehicle. Under M.R.A.P. 28, the Court has no duty to address the State’s contentions on the good-faith exception, because the State’s brief does not address the Court’s precedent on that exception. In addition, the misinterpretation of constitutional mandates, the contradictory information in the arrest report and testimony, and the failure to resolve the suspect’s identity and act accordingly render the good-faith exception inapplicable. Even if the stop was justified at its inception, the officers exceeded the scope required to resolve the driver’s identity. Since the evidence against Eaddy is insufficient to sustain a conviction for possession with intent to distribute without admission of evidence of the illegally obtained cocaine, the conviction is reversed and rendered. |
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