Commonwealth v. Conley

54 Va. Cir. 111, 2000 Va. Cir. LEXIS 624
CourtRichmond County Circuit Court
DecidedAugust 29, 2000
DocketIndictment for Credit Card Theft: F-00-2539; Indictment for Felony Petit Larceny: F-00-2538
StatusPublished

This text of 54 Va. Cir. 111 (Commonwealth v. Conley) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Conley, 54 Va. Cir. 111, 2000 Va. Cir. LEXIS 624 (Va. Super. Ct. 2000).

Opinion

BY JUDGE MARGARET P. SPENCER

The Defendant seeks to suppress evidence procured by a warrantless search of his person by a Virginia Commonwaelth University police officer. After reviewing the Motion to Suppress and the evidence presented at the hearing on the matter, Defendant’s Motipn to Suppress is denied. The search and seizure hete was an investigative detention based on the officer’s reasonable suspicion that the Defendant was engaged in a criminal activity. It therefore fulfills the requisites of a “Terry stop.” Terry v. Ohio, 392 U.S. 1 (1968).

On April 12,2000, at approximately 12:00 p.m., Officer A. J. Reddick was patrolling MCV Hospital when he received a call from the MCV security supervisor alerting him of a “suspect who fit the description of a larceny suspect”’ near the information desk in the main lobby of the hospital. (Transcript at 7,10.) The officer approached this suspect, whom he identified as the Defendant When the officer approached Defendant, the MCV security supervisor was present and informed him that the missing items included wallets and credit cards. (Tr. at 8.)

Officer Reddick observed that Defendant was “fidgety,” “sweating,” and “nervous” and asked him if he had a purpose at MCV. Defendant said that he was a patient in fee ACC building. The officer confirmed feat Defendant was a patient in fee ACC building, but noted that the ACC building does not connect to fee main hospital. (Tr. at 11-12.)

[112]*112Officer Reddick explained to Defendant that he “fit the description of a larceny suspect for the north hospital” and told Defendant he was a suspect in this larceny investigation. (Tr. at 12.) Officer Reddick asked Defendant for permission to pat him down for weapons. When the Defendant did not consent, Officer Reddick gave him his Miranda warnings and Defendant then consented to the pat down for weapons. (Tr. at 12-13.) Upon searching Defendant, Officer Reddick recovered evidence the Commonwealth seeks to admit in Defendant’s trial for larceny and credit card theft. (Tr. at 13.)

Officer Reddick testified the Defendant’s demeanor indicated he might have a weapon and caused the officer to fear for his safety. (Tr. at 19-20.) Defendant seemed nervous. (Tr. at 10.) Defendant also carried a clothing article wrapped around his hand in a manner that suggested he was concealing a weapon. (Tr. at 19.) The officer also noted a large bulge in Defendant’s pocket that could have been a weapon, and the Defendant was not in the area of the hospital where he was receiving medical treatment. (Tr. at 12, 21.) Finally, Officer Reddick testified it was his intention to place Defendant under investigative detention and, therefore, he gave Defendant his Miranda warnings. (Tr. at 16.)

There are three categories of police-citizen confrontations. These categories, which include consensual encounters, Terry stops, and arrests, are discussed below as each categoiy relates to the arguments made by counsel in this case.

Consensual Encounters

In McGee v. Commonwealth, 25 Va. App. 193 (1997), the Court held “[w]hen the police expressly inform an individual that they have received information that the individual is engaging in criminal activity, the police ‘convey a message that compliance with their requests is required’.” Id. at 200. In this situation, a reasonable person would probably not feel free to leave and the detention is a seizure. Id.

Once a seizure has occurred, the police must have a reasonable, articulable suspicion for the detention and may not rely on a defendant’s express or implied consent. Id. at 202. Because the seizure in McGee was unlawful under Terry, the evidence obtained should have been suppressed. Id. at 203.

Officer Reddick told the Defendant he fit the description of a larceny suspect. (Tr. at 12.) In accord with McGee, this action carries significant weight in determining whether a reasonable person would feel free to leave.

[113]*113After telling Defendant he was a larceny suspect, the officer gave Defendant the Miranda rights (Tr. at 12), which are typically given to a person is in police custody. Although the Commonwealth argued that the Miranda warnings actually cured the McGee problem here, this argument is tenuous. Miranda warnings act as a prophylactic cure for Fifth and Sixth Amendment issues, but do not address Fourth Amendment issues. See Miranda v. Arizona, 384 U.S. 436 (1966).

Considering the totality of the circumstances, a reasonable person would not feel free to leave. Thus, the officer’s detention of Defendant was not consensual. It was a seizure under the Fourth Amendment.

Terry Stop

In a lawful Terry stop, an officer who lacks probable cause to arrest may approach and investigate a person suspected of engaging in a criminal activity. See Baldwin v. Commonwealth, 243 Va. 191 (1992) (citing Terry). The officer must have a reasonable, articulable suspicion for the detention. Terry, 392 U.S. at 22. In determining whether an officer possesses this reasonable, articulable suspicion, courts must consider die totality of the circumstances. United States v. Cortez, 449 U.S. 411 (1981).

An anonymous tip which is sufficiently corroborated can furnish the level of suspicion required to make an investigative stop. See McGee, 25 Va. App. at 202. In McGee, the police did not have a reasonable, articulable suspicion when the officer proceeded on an anonymous, uncorroborated tip. The officer did not personally observe any “suspicious activity or furtive gestures by the defendant... nothing that suggested... that the defendant may have been or was about to be engaged in criminal activity.” Id. at 203.

In Jackson v. Commonwealth (Va. App. 2000), on the other hand, the stop was lawful under Terry where the defendant matched the physical description in the anonymous tip and demonstrated suspicious behavior which was observed by the officer. Defendant’s suspicious behavior included walking quickly past the officers, failing to respond to the officer’s questions, and reaching down quickly to fumble with something in his pants. Id.

In this case, Officer Reddick’s information was not provided by an anonymous informant. He received information from the MCV security supervisor and another security employee. (Tr. at 6.) The Defendant not only fit the description of the larceny suspect, but also appeared nervous (Tr. at 10), was unable or refused to explain his presence in a wing of the hospital that was different from the area where he was medically treated (Tr. at 12, 22), wore a clothing article wrapped around his hand in a manner that might [114]*114conceal a weapon (Tr. at 19), and had a large bulge in his pocket that could have been a weapon. (Tr. at 21.) These facts, reliable, identifying information coupled with the officer’s own observations of Defendant, provided a reasonable, articulable suspicion to detain Defendant for further investigation.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
United States v. Cortez
449 U.S. 411 (Supreme Court, 1981)
Smith v. Ohio
494 U.S. 541 (Supreme Court, 1990)
Florida v. JL
529 U.S. 266 (Supreme Court, 2000)
McGee v. Commonwealth
487 S.E.2d 259 (Court of Appeals of Virginia, 1997)
Greenfield v. Commonwealth
204 S.E.2d 414 (Supreme Court of Virginia, 1974)
Baldwin v. Commonwealth
413 S.E.2d 645 (Supreme Court of Virginia, 1992)

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Bluebook (online)
54 Va. Cir. 111, 2000 Va. Cir. LEXIS 624, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-conley-vaccrichmondcty-2000.