Early last week, the Maryland Court of Appeals issued a controversial opinion in the case of Holt v. State of Maryland, holding that a law enforcement officer who has reasonable suspicion that an individual committed a crime may briefly detain the individual to investigate. The Court elaborated, stating that a “series of innocent acts may, taken together, raise reasonable suspicion in the mind of an experienced officer.”
In Holt, the defendant, met in 2011 with an individual who was suspected by Baltimore City Police Detectives of trafficking in heroin and had been under surveillance for an extended period of time. Two weeks to the meeting, Detectives had observed the person that the defendant met with engage in a drug transaction with another individual.
During the meeting between the men, they shook hands, got into a car together and went for a short drive, and parted ways. Following the meeting, Detectives followed the defendant’s vehicle and, after a few minutes, conducted a traffic stop on the vehicle. One of the Detectives testified that they had stopped the defendant because they wanted to identify the individual who may have engaged in a drug transaction with a known drug dealer. The Detective also testified that the defendant had committed two minor traffic violations.
During the encounter, the defendant pointed a firearm at the Detectives, causing them to fire several shots into the vehicle. The defendant fled the scene but was later arrested after checking himself into a hospital with gunshot wounds. The defendant was charged with assault, reckless endangerment, firearms violations, and a drug offense. The defendant moved to suppress evidence discovered from the traffic stop and the trial court agreed, holding that the Detectives did not have reasonable suspicion to stop the defendant and ruling any testimony related to observation of a gun inadmissible. On appeal by the State, the Court of Special Appeals reversed the trial court’s decision and holding that “the stop of the vehicle…was supported by articulable reasonable suspicion.” The Court of Special Appeals further opined that even if the stop was not supported by reasonable suspicion, “the exclusionary rule does not apply” because other crimes committed by the defendant “purged the taint from the unlawful stop.”
The Court of Appeals granted a petition for a writ of certiorari and, upon review, affirmed the Court of Special Appeals reversal. The Court opined that, based upon the Detectives’ observations of the encounter between the men, they had reasonable suspicion sufficient to justify a stop of the defendant to investigate further.
In so holding, the Court deferred to the knowledge and experience of the Detectives with drug transactions, concluding that the Detectives had “articulated specific characteristics of that meeting that, when viewed through the lens of a trained law enforcement officer, support the…suspicion that [the defendant] committed a crime.” Accordingly, because the Detectives had reasonable suspicion to conduct the stop of the defendant, he was not entitled to suppression of any of the observations made during and immediately following the investigatory stop.
The criminal defense attorneys of Brassel, Alexander & Rice, LLC have extensive experience defending the Constitutional rights of individuals that have been charged with a crime. If you or someone you know has been charged with a crime in Maryland, contact the attorneys of Brassel, Alexander & Rice, LLC today.