Stokes v. State, 362 Md. 407

Summary

The Court of Appeals of Maryland held that a police officer lacked reasonable articulable suspicion to stop and frisk Glen Keith Stokes near the scene of a recently reported robbery based primarily on his race, dark clothing, location, and allegedly hurried conduct. The court concluded that the sparse description did not sufficiently narrow the class of potential suspects and that the search violated the Fourth Amendment. It reversed the denial of Stokes's motion to suppress and held that the seized evidence should have been excluded.

Holdings

1. The stop was unconstitutional because, viewed under the totality of the circumstances, the officer had only an unparticularized hunch that Stokes was the robbery perpetrator. A generic description consisting principally of race and dark clothing, combined with proximity to the crime and hurried driving, did not establish reasonable articulable suspicion.
2. The motion to suppress should have been granted because the pat-down and ensuing searches were fruits of the unlawful stop.

Questions Presented

1. Whether the officer had reasonable articulable suspicion under the Fourth Amendment to stop and detain Stokes as the possible perpetrator of the nearby robbery.
2. Whether the evidence discovered during the pat-down and ensuing searches had to be suppressed as fruits of an unlawful seizure.

Disposition

reversed_and_remanded