Randolph v. The State

Summary

The Georgia Court of Appeals considered an interlocutory appeal from the denial of Stanley Randolph's motion to suppress evidence obtained during a police detention and search. The court held that officers lacked a reasonable, articulable suspicion to justify the second-tier investigative detention based on the circumstances observed before the detention. It reversed the trial court's order denying suppression.

Holdings

1. The encounter was a second-tier investigative detention because the officers blocked the sedan from leaving and testified that Randolph was not free to leave.
2. The officers lacked a particularized and objective basis to reasonably suspect that Randolph was engaged in or had engaged in criminal activity before the detention.
3. Because the detention was unsupported by reasonable articulable suspicion, the trial court erred in denying Randolph's motion to suppress evidence obtained as a result of the detention and subsequent search.

Questions Presented

1. Whether the officers' conduct constituted a second-tier investigative detention rather than a consensual first-tier encounter.
2. Whether the officers had a particularized and objective basis, or reasonable articulable suspicion, to detain Randolph before observing the suspected marijuana.
3. Whether the evidence obtained during the detention and subsequent searches should be suppressed as the fruit of an unlawful detention.

Disposition

reversed