State v. Stevens, 2019 MT 36, 394 Mont. 278

Summary

The Montana Supreme Court affirmed the denial of Jeremiah James Stevens's motion to suppress evidence and statements arising from an investigative stop. The court held that the officer had particularized suspicion to initiate the stop and that using handcuffs did not convert the stop into an arrest because the restraint was reasonably necessary for officer safety. Stevens's spontaneous admission that he possessed methamphetamine provided probable cause for his arrest and the ensuing search.

Holdings

1. The officers had particularized suspicion to initiate a Terry stop because Stevens's conduct—hiding and bobbing in bushes across from a courthouse at approximately 6:00 a.m., near a prisoner-transport area—provided objective data supporting reasonable inferences of wrongdoing or a potential threat to the prisoner transport.
2. The officers' use of handcuffs did not convert the lawful investigative stop into an arrest because the handcuffs were used as a reasonably necessary officer-safety measure while the officers investigated suspicious conduct, and the deputy intended to conduct a Terry stop rather than effect an arrest.
3. The officers had probable cause to arrest Stevens after he spontaneously stated during the lawful investigative stop that he possessed methamphetamine.

Questions Presented

1. Whether the officers had particularized suspicion to initiate a temporary investigative stop.
2. Whether the immediate use of handcuffs transformed the investigative stop into an arrest unsupported by probable cause.
3. Whether the officers had probable cause to arrest Stevens after he stated that he possessed methamphetamine.

Disposition

affirmed