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United States v. Charlie Clarence King

Citations: 842 F.2d 311; 1988 U.S. App. LEXIS 8850; 1988 WL 26467Docket: 87-8747

Court: Court of Appeals for the Eleventh Circuit; April 15, 1988; Federal Appellate Court

Narrative Opinion Summary

The case centers on the United States Court of Appeals for the Eleventh Circuit's affirmation of a district court's decision regarding a pat-down search of an individual suspected of armed robbery. The appellant was suspected of involvement in a bank robbery where money with a red dye pack was stolen. An off-duty officer reported that the appellant had passed red-dye-stained bills at a lounge, raising suspicion of his involvement in the robbery. During a subsequent interaction, the appellant consented to a pat-down for weapons, conducted by an officer concerned for his safety. This search revealed cash and a pipe, and the appellant was subsequently charged with the robbery. The appellant's motion to suppress the evidence obtained from this pat-down was denied. On appeal, the appellant challenged the sufficiency of grounds for the pat-down. However, the court found that the officer's actions were justified based on reasonable suspicion and safety concerns, thus affirming the lower court's ruling. The court underscored the principle that not all police-citizen interactions invoke Fourth Amendment protections, especially when brief encounters are based on reasonable suspicion of criminal activity.

Legal Issues Addressed

Affirmation of Lower Court Decision

Application: The appellate court affirmed the district court’s denial of the motion to suppress evidence obtained during the pat-down, holding that the officer acted within legal bounds.

Reasoning: The district court's decision was affirmed.

Consent to Search

Application: The defendant consented to a pat-down for weapons, which was conducted before entering the patrol car, justifying the search as a precautionary measure for officer safety.

Reasoning: Morton requested to pat him down for weapons before allowing him in the patrol car, to which King consented.

Fourth Amendment Protections

Application: The court held that Fourth Amendment protections do not extend to all interactions between police and citizens, particularly when officers have reasonable suspicion of criminal activity.

Reasoning: Fourth Amendment protections do not extend to all interactions between police and citizens. Officers can approach individuals in public, identify themselves, and ask questions without coercion.

Justification for Pat-down Search

Application: The court found the pat-down search justified due to the officer's reasonable suspicion and safety concerns during the encounter.

Reasoning: His decision to conduct a pat-down for weapons was justified as his safety concerns remained unaddressed during the encounter.

Reasonable Suspicion

Application: In this case, the officer's suspicion that the defendant could be armed was justified given the context of the red dye-stained money, which was linked to a bank robbery.

Reasoning: Brief encounters are permitted when officers have reasonable suspicion of criminal activity. In this case, Officer Morton had been informed about King possessing red dye-stained money, indicative of bank robbery, and recognized that such scenarios often involve armed individuals.