State v. Whitaker

795 P.2d 182, 58 Wash. App. 851, 1990 Wash. App. LEXIS 325
CourtCourt of Appeals of Washington
DecidedAugust 20, 1990
Docket23557-5-I
StatusPublished
Cited by20 cases

This text of 795 P.2d 182 (State v. Whitaker) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Whitaker, 795 P.2d 182, 58 Wash. App. 851, 1990 Wash. App. LEXIS 325 (Wash. Ct. App. 1990).

Opinions

Webster, J.

— Kenneth S. Whitaker appeals his conviction of possession of a controlled substance arguing that evidence was unlawfully obtained from him. We affirm.

[852]*852Facts

Two officers of the Seattle Police Department knew Whitaker from encountering him and other members of his gang which had claimed the Garfield Park area, Seattle, as their territory. The officers regularly patrolled this park because of a high incidence of gang violence occurring in and around it. At times, two or three shootings per night were taking place; the police received "constant reports of shots fired." By simply walking through the park, the officers would uncover weapons (handguns, sawed-off shotguns, knives, bats, clubs) stashed in places such as garbage cans and bushes near where Whitaker and his gang would "hang out". The police would regularly talk to Whitaker to gather intelligence concerning gang activities because he was known to the police as the leader of the gang that had claimed Garfield Park as its territory. Nearly every time the police officers encountered Whitaker, they patted him down for weapons but found none on his person.

On June 26, 1988, at about 12:30 a.m., the two police officers patrolled the park in a marked police car, in uniform. After spotting several people at a picnic table, the officers exited the patrol car and walked toward the group. One of the officers carried a flashlight and could identify Whitaker standing among his companions. When the officers neared, Whitaker dropped a red plastic bottle on the ground. One of the officers confiscated the bottle and found it contained rock cocaine. The officers arrested Whitaker and retrieved more cocaine from his pocket.

The State charged Whitaker on August 22, 1988, with possession of cocaine. On November 7, 1988, Whitaker moved to suppress the evidence seized from him. Whitaker claimed that he discarded the cocaine when he saw the police approaching and looking at him because he expected them to frisk him as they had done in the past. He further felt that had he attempted to leave, the police officers would have stopped and searched him. The court found that although Whitaker reasonably believed that he would have been detained and searched when he saw the officers [853]*853approaching, Whitaker abandoned the drugs such that the police lawfully retrieved them from the ground. The court denied his motion and convicted Whitaker as charged.

Discussion

Generally, the police may retrieve voluntarily abandoned property without violating Fourth Amendment rights. State v. Serrano, 14 Wn. App. 462, 464, 470, 544 P.2d 101 (1975); see also State v. Swaite, 33 Wn. App. 477, 485 n.5, 656 P.2d 520 (1982); State v. Tidwell, 23 Wn. App. 506, 508, 597 P.2d 434 (1979). Whitaker argues that he involuntarily abandoned the cocaine due to illegal police conduct. Courts of other jurisdictions have announced a rule that if a suspect discards property in response to illegal police conduct, the police may not retrieve the property without invading a suspect's Fourth Amendment rights. See, e.g., United States v. Tolbert, 692 F.2d 1041, 1045 (6th Cir. 1982) (suspect's disclaimer of ownership of property deemed involuntary when done in response to unconstitutional seizure or arrest), cert. denied, 464 U.S. 933 (1983); Fletcher v. Wainwright, 399 F.2d 62 (5th Cir. 1968) (involuntary abandonment occurred when illegal entry into motel room prompted occupants to jettison stolen jewelry out window). Involuntary abandonment requires (1) unlawful police conduct and (2) a causal nexus between the unlawful conduct and the abandonment. See United States v. Roman, 849 F.2d 920, 923 (5th Cir. 1988).

Whitaker argues that the police officers engaged in unlawful conduct prior to his abandonment of the cocaine. Specifically, Whitaker maintains that when the officers drove into the park and walked toward him, they illegally seized him. This argument is without merit.

When analyzing if a seizure has occurred, " [t]he essential inquiry is whether, under the circumstances, a reasonable person would believe he was not free to leave." State v. Machado, 54 Wn. App. 771, 775, 775 P.2d 997 (1989) (citing Immigration & Naturalization Serv. v. Delgado, 466 U.S. 210, 216, 80 L. Ed. 2d 247, 104 S. Ct. 1758 [854]*854(1984); United States v. Mendenhall, 446 U.S. 544, 554, 64 L. Ed. 2d 497, 100 S. Ct. 1870 (1980)), review denied, 114 Wn.2d 1009 (1990). In deciding what constitutes a seizure, we have consistently required more intrusive police conduct than the simple act of an officer walking toward a suspect in a park: see, e.g., State v. DeArman, 54 Wn. App. 621, 624, 774 P.2d 1247 (1989) (seizure occurs when police pull behind another vehicle and activate emergency lights); State v. Ellwood, 52 Wn. App. 70, 73, 757 P.2d 547 (1988) (seizure occurs when police tell suspect, "'[w]ait right here'"); State v. Sweet, 44 Wn. App. 226, 230, 721 P.2d 560 (seizure occurs when officer calls out, '"Halt! Police!"'), review denied, 107 Wn.2d 1001 (1986); see also State v. Stroud, 30 Wn. App. 392, 634 P.2d 316 (1981), review denied, 96 Wn.2d 1025 (1982). It is well settled that a mere request for information does not constitute a seizure. State v. Machado, 54 Wn. App. at 775; Ellwood, 52 Wn. App. at 73; see also State v. Aranguren, 42 Wn. App. 452, 455-56, 711 P.2d 1096 (1985) (no seizure where officer signaled suspects on bikes saying, '"can I talk to you guys for a minute'"). "Whether a reasonable person would believe he was detained depends on the particular, objective facts surrounding the encounter." Ellwood, 52 Wn. App. at 73 (citing Mendenhall, 446 U.S. at 554). Contrary to Whitaker's position, this "reasonable person" standard does not depend upon the subjective perceptions of the suspect. 3 W. LaFave, Search and Seizure § 9.2(h), at 407 (2d ed. 1987).

Whitaker dropped the container of cocaine when the police officers were several feet away from him. They had not yet said a word to him nor had they made any gestures, such as hand movements or drawing weapons. Whitaker believes that because he was seized by the same officers in previous, identical situations, any reasonable person in his position would feel restricted from leaving.

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State v. Whitaker
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Bluebook (online)
795 P.2d 182, 58 Wash. App. 851, 1990 Wash. App. LEXIS 325, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-whitaker-washctapp-1990.