Dozier v. United States

Summary

The District of Columbia Court of Appeals held that police officers seized Samuel D. Dozier by the time he complied with their request to place his hands against a wall for a pat-down. Because the officers lacked reasonable, articulable suspicion, the pat-down violated the Fourth Amendment, and the cocaine and other evidence obtained thereafter were fruits of that violation. The court reversed Dozier’s conviction for possession of cocaine with intent to distribute and remanded for further proceedings.

Holdings

1. Dozier was seized within the meaning of the Fourth Amendment by the time he complied with the officers' request to put his hands against the alley wall for a pat-down.
2. The seizure was unlawful because the officers lacked reasonable, articulable suspicion that Dozier was engaged in criminal activity before the seizure occurred.
3. The cocaine and the officers' testimony concerning Dozier's flight and throwing motion were fruits of the unlawful seizure and should have been suppressed.
4. Dozier's discarding of the cocaine while fleeing did not defeat suppression because the abandonment was a consequence of the unlawful seizure and was therefore involuntary.

Questions Presented

1. Whether the police encounter became a seizure under the Fourth Amendment by the time Dozier submitted to the officers' request to place his hands against a wall for a pat-down.
2. Whether the seizure was supported by reasonable, articulable suspicion.
3. Whether the cocaine and evidence of Dozier's flight and discarding of the cocaine were fruits of the unlawful seizure and therefore subject to suppression.
4. Whether Dozier's abandonment of the cocaine after fleeing eliminated his ability to challenge its seizure.

Disposition

reversed_and_remanded