{"id":2469,"date":"2008-12-24T10:22:21","date_gmt":"2008-09-20T15:33:50","guid":{"rendered":""},"modified":"-0001-11-30T00:00:00","modified_gmt":"2008-09-20T15:33:50","slug":"en-US","status":"publish","type":"post","link":"http:\/\/fourthamendment.com\/?p=2469","title":{"rendered":"MD: Trained narc credited on reasonable suspicion"},"content":{"rendered":"

Trained narcotics officers had reasonable suspicion that defendant was involved in drugs before his flight from them. State v. Dick<\/a>, 181 Md. App. 693, 957 A.2d 150 (2008):<\/p>\n

In our opinion, prior to Dick’s flight and at the time of the stop, the police had reasonable suspicion that he was involved in illegal drug activity. The police officers were specialists in drug enforcement. The area and the specific location under surveillance were known for illegal drug activity and, in fact, two of the officers had previously arrested persons at the gas station for such crimes. Contrast Lemmon<\/em>, supra, 318 Md. at 380. The location was not a recreational area or meeting place, so that Hoffman’s persistent bicycle riding and apparent wait for someone was out of the ordinary. The quick hand-to-hand transaction in an area more remote than the gas station, although not positively identified as a drug sale, was more than two men talking. Contrast Lemmon<\/em>, supra, 318 Md. at 379-80. It was recognized by the officers as characteristic of such illegal activity. Although Ward and Stricklin did not see the transaction themselves, they were not acting upon an anonymous tip, but upon eye-witness information received from fellow officers, who also knew the hallmarks of drug activity. Contrast Lemmon<\/em>, supra, 318 Md. at 379. In addition, there were reasons to make a stop. Ward and Stricklin did not know which of the two suspects was the buyer or seller or whether either displayed signs of using drugs, and a brief delay, while the other officers confronted Hoffman, could have provided vital information. Clearly, the police were acting “in a swiftly developing situation.” United States v. Sharpe<\/em>, supra, 470 U.S. at 686. Finally, the stop itself was for the briefest of periods.<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"

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