William Mack Gross pled guilty to violating the habitual motor vehicle offender law while reserving the right to appeal a certified legal question regarding the constitutionality of his vehicle stop by law enforcement. The specific issue was whether the stop, initiated based on a citizen report of a "suspicious vehicle," violated his Fourth Amendment rights against unreasonable searches and seizures. The trial court denied Gross's motion to suppress evidence obtained from the stop.
During the suppression hearing, Officer Larry Nabors testified that he was dispatched at 2:00 a.m. to investigate a report of a suspicious vehicle in a trailer park. The report stemmed from a woman claiming she had been followed by a decommissioned police vehicle. Officer Nabors did not initially locate the vehicle but later stopped it after observing it leaving the trailer park. He acknowledged that there was no evidence of illegal activity associated with the vehicle and that the stop was solely to question the driver about his presence in the trailer park.
The appellate court reviewed the record and concluded that the trial court had erred in denying the motion to suppress. The court emphasized that factual findings from suppression hearings are typically upheld unless contradicted by the evidence, but the legal application of these facts is reviewed de novo. The Fourth Amendment and the Tennessee Constitution both protect individuals from unreasonable searches and seizures, reinforcing the court's decision to reverse the trial court's judgment and dismiss the indictment against Gross.
A search without a warrant is inherently unreasonable unless it falls under a specific exception. Evidence obtained from such a search may be suppressed unless the prosecution proves, by a preponderance of the evidence, that the search met an exception to the warrant requirement. One exception allows for temporary seizure if a police officer has reasonable suspicion based on specific and articulable facts that a crime has occurred, is occurring, or will occur. This applies to investigative stops of vehicles as well.
When assessing reasonable suspicion, courts consider the totality of the circumstances, including the officer’s observations, information from other officers or citizens, and known offender patterns. The officer’s inferences and deductions, which may not be apparent to untrained individuals, are also relevant. A seizure occurs when, under the circumstances, a reasonable person would believe they are not free to leave, such as when police activate their vehicle’s lights.
In the case at hand, there is consensus that Defendant was seized when Officer Nabors activated his lights. The key question is whether the stop was constitutional based on reasonable suspicion. While Officer Nabors expressed concern regarding Defendant’s vehicle following a woman to a trailer park, he could not provide specific facts establishing reasonable suspicion of criminal activity. The vehicle had only been at the trailer park for about ten minutes and left shortly after Nabors arrived. Thus, there was insufficient basis to suspect any crime had been committed by Defendant or the vehicle’s occupants.
Officer Nabors acknowledged that he had no reason to suspect any illegal activity involving Defendant's vehicle or any crime associated with it. He did not witness any law violations as the vehicle left the trailer park and could not identify any facts indicating that Defendant was engaged in criminal conduct. Nabors admitted that the vehicle was stopped not due to any suspected illegal activity but solely to ascertain why it was present in the trailer park. Consequently, there were no specific and articulable facts to justify a reasonable suspicion of criminal activity. As Nabors did not claim to have such a suspicion, the stop violated the Fourth Amendment and Article I, Section 7, necessitating the suppression of any evidence obtained as a result. Therefore, the trial court's judgment should be reversed, and the case dismissed.
