{"id":9681,"date":"2014-01-08T08:13:05","date_gmt":"2013-10-29T23:13:27","guid":{"rendered":""},"modified":"-0001-11-30T00:00:00","modified_gmt":"2013-10-29T23:13:27","slug":"en-US","status":"publish","type":"post","link":"http:\/\/fourthamendment.com\/?p=9681","title":{"rendered":"MD: Merely hanging out with a drug dealer is not reasonable suspicion for a stop, but here there was more"},"content":{"rendered":"<p>Merely hanging out with a drug dealer is not reasonable suspicion for a stop, but here there was more, and it indicated that defendant was a drug dealer too. Therefore, the stop was valid. <a href=\"http:\/\/www.mdcourts.gov\/opinions\/coa\/2013\/98a12.pdf\">Holt v. State<\/a>, 435 Md. 443, 78 A.3d 415 (2013):<\/p>\n<p><!--more--><\/p>\n<blockquote><p>For its part, the State concedes, as it must, that an individual&#8217;s association with a drug dealer does not, by itself, create reasonable suspicion that the individual committed a drug-related crime. Petitioner and the State, however, part ways over the question of whether Petitioner&#8217;s association with Blue provided the sole basis for the detectives&#8217; suspicion that Petitioner committed a crime. That is the central question we must answer.<\/p>\n<p>&#8230; We therefore look to the entire record to determine whether, viewed objectively, a law enforcement officer, knowing what the detectives in the present case knew, would harbor the requisite reasonable suspicion that Petitioner had committed a drug-related offense.<\/p>\n<p>Here, the detectives testified about several factual parallels between the meeting at Lake Montebello and Blue&#8217;s drug transaction with Townsend approximately two weeks earlier. With respect to Blue&#8217;s behavior, the detectives testified that he looked around throughout his meeting with Petitioner the same way he had looked around throughout the drug transaction with Townsend. As for the nature of the meetings, the detectives testified that they lasted roughly the same amount of time (merely two minutes, or so), both started in public places, Townsend and Petitioner were waiting for Blue in what appears to be prearranged locations, and Townsend and Petitioner parted ways with Blue after those brief meetings. Accordingly, the specific characteristics of the meeting between Petitioner and Blue\u2014and not merely Petitioner&#8217;s &#8220;proximity to [a person] associated with drug activity&#8221; or his &#8220;brief interaction with a known suspect&#8221;\u2014supported the detectives&#8217; suspicion that Petitioner had committed a drug-related crime.<\/p>\n<p>We necessarily defer to the training and experience of Detectives Crystal and McShane. &#8230;\n<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"<p>b2evALnk.b2WPAutP <a class=\"more-link\" href=\"http:\/\/fourthamendment.com\/?p=9681\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"","ping_status":"pingsdone","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[],"tags":[],"class_list":["post-9681","post","type-post","status-publish","format-standard","hentry"],"_links":{"self":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/9681","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=9681"}],"version-history":[{"count":0,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/9681\/revisions"}],"wp:attachment":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=9681"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=9681"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=9681"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}