Minnesota v. Dickerson

Facts of the Case

Summary of the Facts

On Novemeber 9, 1989, while exiting an apartment building with a history of cocaine trafiicking, Timothy Dickerson spotted police officers and turned to walk in the opposite direction. In response, the officers commanded Dickerson to stop and proceeded to frisk him. An officer discovered a lump in Dickerson's jacket pocket, and, upon further tactile investigation, formed the belief that it was cocaine. The officer reached into Dickerson's pocket and confirmed that the lump was in fact a small bag of cacaine. In affirming, the State Supreme Court held that both the stop and the frisk of the respondent were valid under Terry v. Ohio, 392 U.S. 1, but found the seizure of the cocaine to be unconstitutional. Refusing to enlarge the "plain-view" exception to the Fourth Amendment's warrant requirement, the court appeared to adopt a cetegorical rule barring the seizure of any contraband detected by an officer through the sense of touch during a patdown search. The court further noted that, even if it recognized such a "plain-feel" exception, the search in this case would not qualify because it went far beyond what if permissible under Terry.

What is in dispute?

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Issue

When a police officer detects contraband through his or her sense of touch during a protective patdown search, does the Fourth Amendment permit its seizure subsquent introduction into evidence?

Was the police officer who frisked Dickerson adhering to the Fourth Amendment when he formed the belief, through his sense of touch, that the lump in Dickerson's jacket pocket was cocaine?

What is the ruling by the court?

Holding

In an unanimous opinion authored by Justice Byron R. White, the court recalled that a police officer may seize contraband when it's in plain sight, "it's incriminating character is immediately apparent." The court also concluded that the police officer frisking Dickerson stepped oustide the boudaries outlined in Terry v. Ohio which requires a protective pat-down search to involve only what is necessary for the detection of weapons.

What facts did the court use?

Opinion/ Reasoning

The officer that frisked Dickerson was already aware that Dickerson's jacket pocket did not contain a weapon, when he detcted the cocaine through further tactile investigation. The court reasoned that the tactile detection of contraband during a lawful pat-down search does not constitute any further invasion of privacy, therefore warrantless seizure was permissible.

~ Minnesota v. Dickerson." Oyez, www.oyez.org/cases/1992/91-2019. Accessed 25 Oct. 2022.

References

~ https://supreme.justia.com/cases/federal/us/508/366/