You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

State v. Hughes

Citations: 765 So. 2d 423; 2000 WL 722287Docket: 99-KA-2554

Court: Louisiana Court of Appeal; May 31, 2000; Louisiana; State Appellate Court

Narrative Opinion Summary

This case involves Richard Hughes, who was charged with possession of crack cocaine following a stop and search by police officers. The primary legal issues centered around the validity of the stop and search, specifically the reasonable suspicion required under Terry v. Ohio and the application of the 'plain feel' doctrine. Hughes was initially detained after officers observed him acting suspiciously near a grocery store. He argued that the officers lacked reasonable suspicion for the stop and that the search exceeded the permissible scope. The trial court denied Hughes' motion to suppress the evidence, leading to his conviction and sentencing to three years of hard labor. Upon appeal, the court reversed the conviction, concluding that the officer's observations were insufficient to establish reasonable suspicion and that the 'plain feel' doctrine did not justify the seizure of the cocaine. The dissenting opinion argued in favor of the officers' actions, emphasizing the need to consider their experience and the totality of the circumstances. Ultimately, the decision highlighted the balance between officer safety and the protection of constitutional rights against unreasonable searches and seizures.

Legal Issues Addressed

Fourth Amendment and Terry Stops

Application: The court considered whether the stop of Hughes met the standards established in Terry v. Ohio for reasonable suspicion and lawful investigatory stops.

Reasoning: Hughes contested the legality of the stop, arguing the officers lacked reasonable suspicion for the stop as defined by Terry v. Ohio, and claimed that any valid stop was exceeded by an unlawful search.

Plain Feel Doctrine

Application: The court assessed whether the seizure of cocaine during a pat-down was justified under the 'plain feel' exception.

Reasoning: Officer Parker's testimony failed to demonstrate that he felt anything in Hughes' pocket that could be recognized as contraband, and he provided no basis for suspecting illegal drugs were present.

Reasonable Suspicion for Investigatory Stop

Application: The court evaluated whether Officer Parker had reasonable suspicion to detain Hughes based on his actions near the grocery store.

Reasoning: The officer observed Mr. Hughes placing a white object into his pocket and subsequently detained him upon entering the grocery store.

Requirements for Frisk During Stop

Application: The court analyzed whether the officers had a reasonable basis to believe Hughes was armed and dangerous to justify a frisk.

Reasoning: A lawful stop does not automatically authorize a pat-down unless the officer reasonably suspects danger.

Totality of Circumstances in Determining Reasonable Suspicion

Application: The opinion emphasized the need to evaluate the totality of the circumstances, considering the officer's experience and the suspect's behavior.

Reasoning: The dissent also reiterated the importance of considering the officers' experience and the context of their actions in determining the justification for the investigatory stop.