Commonwealth v. Fitchett

77 Va. Cir. 108, 2008 Va. Cir. LEXIS 240
CourtChesapeake County Circuit Court
DecidedSeptember 16, 2008
DocketCase No. CR08-2297
StatusPublished

This text of 77 Va. Cir. 108 (Commonwealth v. Fitchett) is published on Counsel Stack Legal Research, covering Chesapeake 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. Fitchett, 77 Va. Cir. 108, 2008 Va. Cir. LEXIS 240 (Va. Super. Ct. 2008).

Opinion

By Judge Randall D. Smith

Defendant stands indicted in this Court on a charge of possession of a firearm after having been convicted of a felony. The matter is now before this Court on Defendant’s Motion to Suppress the firearm in question. Defendant argues that discovery of the firearm was based upon an illegal seizure of Defendant in violation of his Constitutional rights. Specifically, Defendant claims that he surrendered to the show of authority and was therefore seized within the meaning of the Fourth Amendment. Consequently, Defendant contends that the firearm was the fruit of an illegal search and should therefore be suppressed. The Commonwealth and Defendant’s counsel argued this case on July 29, 2008, and later submitted briefs. The Court stands ready to rule.

Facts

On February 24,2008, Officer Blount responded to a loud music call at 1:15 a.m. in the area of Schooner Trail and Cutter Court in the City of Chesapeake. While responding, Blount observed two males standing beside each other in the roadway of Cutter Court. One of the males, later identified as Carlos Fitchett, was holding a cup in his hand. As soon as the two males saw the police vehicle, they turned their backs to Blount and stood shoulder to [109]*109shoulder for ten seconds. When they turned around, the Defendant did not have the cup. At that point, Officer Blount got out of his vehicle and began to approach. The two individuals began to walk away.

Officer Blount suspected Fitchett of having an open container of alcohol. Fte told both individuals to stop and asked if they were hiding anything from him. Fitchett replied that he was not hiding anything from him. Blount indicated that given the area where he was located, the time in the morning, and the behavior he had just observed, that he had concerns for his own safety. He advised Fitchett to turn around and put his hands on top of his head. At that time Blount’s intention was to conduct a pat-down frisk of Fitchett for “officer safety.” Fitchett turned and put his hand up in the air but did not lock his fingers together. Fitchett repeatedly looked back over his shoulder as if to see exactly where he was in relation to Officer Blount. As Officer Blount came close to Fitchett and just touched Fitchett’s hands, Fitchett fled on foot before Blount was able to perform the pat-down. Blount began a foot pursuit of Fitchett. Fitchett ran up a driveway on Cutter Court and tripped. As Fitchett started to fall, Blount observed a handgun fall from Fitchett’s waistband to the ground on the driveway. Fitchett was then immediately taken into custody.

Arguments

Defendant argues, first, that California v. Hodari D, 499 U.S. 621 (1991), does not apply because, in that case, Defendant never complied with the police officer’s commands, whereas, here, Defendant intentionally was compliant and that Blount physically touched Defendant which resulted in a seizure; second, Defendant relies on the holding in Roulhac v. Commonwealth, 50 Va. App. 8, 14, 646 S.E.2d 4, 7 (2007), which stated that, once the officer touched Defendant’s wrist, the seizure occurred for Fourth Amendment purposes.

The Commonwealth argues that Hodari D applies here because Defendant never surrendered to the authority of the police officer and, therefore, was not seized under the Fourth Amendment.

Discussion

Police-citizen encounters typically fall into one of three categories for constitutional analysis. First, there are consensual encounters that occur in public places and do not implicate the Fourth Amendment. Second, are brief investigatory stops that must be based upon a reasonable, articulable suspicion [110]*110that criminal conduct is or may be occurring (“Terry stops”). Last is the full-scale arrest or searches that must be based upon probable cause. Roulhac v. Commonwealth, 50 Va. App. 8, 14, 646 S.E.2d 4, 7 (2007).

The Court in Roulhac quoted the Supreme Court by noting that “[l]aw enforcement officers do no violate the Fourth Amendment’s prohibition of unreasonable seizures merely by approaching individuals on the street or in other public places and putting questions to them if they are willing to listen.” Roulhac, 50 Va. App. at 14, 646 S.E.2d at 7 (quoting United States v. Drayton, 536 U.S. 194, 200, 122 S. Ct. 2105, 2110 (2002)). The Court continues by noting:

In addition, “[a]n encounter between a law enforcement officer and a citizen in which the officer merely identifies himself and states that he is conducting an ... investigation, without more, is not a seizure within the meaning of the Fourth Amendment but is, instead, a consensual encounter.” Londono v. Commonwealth, 40 Va. App. 377, 399, 570 S.E.2d 641, 651 (2003) (quoting McGee v. Commonwealth, 25 Va. App. 193, 199, 487 S.E.2d 259, 262 (1997)). Likewise, “interrogation relating to one’s identity or request for identification by the police does not, by itself, constitute a Fourth Amendment seizure.” INS v. Delgado, 466 U.S. 210, 216, 104 S.Ct. 1758, 1762 (1984). Such encounters are consensual. “Fourth Amendment scrutiny is triggered, however, the moment an encounter Toses its consensual nature’.” Payne v. Commonwealth, 14 Va. App. 86, 88, 414 S.E.2d 869, 870 (1992) (citation omitted).

“In order for any seizure to occur, an individual must be under some physical restraint by an officer or have submitted to the show of police authority.” Thomas v. Commonwealth, 24 Va. App. 49, 54, 480 S.E.2d 135, 137 (1997). An encounter between a police officer and a citizen becomes a seizure for Fourth Amendment purposes “only if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave,” Baldwin v. Commonwealth, 243 Va. App. 191, 196, 413 S.E.2d 645, 648 (1992) (quoting United States v. Mendenhall, 446 U.S. 544, 554, 100 S.Ct. 1870, 1877 (1980)), because the citizen’s freedom of movement was being restrained by the use of physical force or show of authority. Hodari D, 499 U.S. at 626-627, 11 S. Ct. at 1550-51.

[111]*111Among the factors which determine whether an officer “by means of physical force or a show of authority” would cause a reasonable person to feel seized, Mendenhall, 446 U.S. at 553, 100 S. Ct. at 1877, are the “threatening presence of several officers, the display of a weapon by an officer, some physical touching of the person of the citizen, or the use of language or tone of voice indicating that compliance with the officer’s request might be compelled.” Londano, 40 Va. App.

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Related

Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
United States v. Mendenhall
446 U.S. 544 (Supreme Court, 1980)
Immigration & Naturalization Service v. Delgado
466 U.S. 210 (Supreme Court, 1984)
Brower Ex Rel. Estate of Caldwell v. County of Inyo
489 U.S. 593 (Supreme Court, 1989)
California v. Hodari D.
499 U.S. 621 (Supreme Court, 1991)
United States v. Drayton
536 U.S. 194 (Supreme Court, 2002)
McCain v. Com.
659 S.E.2d 512 (Supreme Court of Virginia, 2008)
Roulhac v. Commonwealth
646 S.E.2d 4 (Court of Appeals of Virginia, 2007)
Londono v. Commonwealth
579 S.E.2d 641 (Court of Appeals of Virginia, 2003)
McGee v. Commonwealth
487 S.E.2d 259 (Court of Appeals of Virginia, 1997)
Thomas v. Commonwealth
480 S.E.2d 135 (Court of Appeals of Virginia, 1997)
Upshaw v. State
570 S.E.2d 640 (Court of Appeals of Georgia, 2002)
Payne v. Commonwealth
414 S.E.2d 869 (Court of Appeals of Virginia, 1992)
Baldwin v. Commonwealth
413 S.E.2d 645 (Supreme Court of Virginia, 1992)

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Bluebook (online)
77 Va. Cir. 108, 2008 Va. Cir. LEXIS 240, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-fitchett-vaccchesapeake-2008.