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On November 9th 1989 Timothy Dickerson was leaving an apartment building known for cocaine trafficking. When he was recognized by police officers he turned the opposite direction. In reaction to that the officers ordered Dickerson to stop. They began to frisk him and that's when they spotted a lump on Dickersons jacket pocket.
The officer reached into his pocket because he beleived that Dickerson was trying to hide something. The lump did end up being a small bag of cocaine. Dickerson was charged with possession of a controlled substance.
In an Unanimous decision, the court recalled that a police officer is permitted to seize contraband when it is in plane sight and when their incrimniating character is instantly evident.
Unanimous decison made by: Justice Rehnquist, White, Blackmun, Stevens, O'Conner, Scalia, Kennedy, Souter, Thomas
The court reasoned that tactile detection of contraband during a lawful pat-down does not act as an invasion of privacy so the warrantless seizure was acceptable.
In contrast, they also mentioned that the police officer who fricked Dickerson stepped outside the bounderies outlined in Terry v. Ohio.
A protective pat-down search is only required when there is detection of weapons. The police officer was already aware that Dickerson did not hold any weapons in his jacket.
https://www.youtube.com/watch?v=3tprwMjc-OA
Minnesota v. Dickerson. (n.d.). Oyez. Retrieved October 26, 2022, from https://www.oyez.org/cases/1992/91-2019