Terry Stops & Exclusion

Day 3: Beyond Probable Cause — The Science of Suspicion

The Terry Doctrine

In Terry v. Ohio, the Supreme Court recognized that the police need a flexible tool for street encounters that don't quite reach Probable Cause.

Terry v. Ohio

The Two-Step Analysis

1. The Stop: A brief investigatory seizure. Requires Reasonable Suspicion that criminal activity is afoot.

2. The Frisk: A pat-down of outer clothing. Requires separate Reasonable Suspicion that the suspect is armed and dangerous. This is for officer safety, not evidence gathering.

Minnesota v. Dickerson

Plain Feel Doctrine

During a Terry frisk, if an officer feels an object whose incriminating nature is immediately apparent (without manipulation), they may seize it. If they have to squeeze or slide it to figure out it's drugs, the seizure is unconstitutional.

The Suspicion Scale

Move the slider to see the legal standard required for different police actions.

Hunch

No legal justification. Police may not seize or search.

Special Needs Searches

Sometimes, the "special needs" of the government outweigh the Fourth Amendment warrant requirement. These are non-investigative in nature.

Public Schools

Administrators only need Reasonable Suspicion to search students. Warrants are not required for maintaining discipline (T.L.O.).

Checkpoints

Sobriety and Border checkpoints are legal because they are standardized and serve a safety/sovereignty goal (Sitz).

The Exclusionary Rule

A judicial remedy that prohibits the use of illegally obtained evidence at trial.

The Poisonous Tree (Initial Illegal Act)
The Fruit (Evidence discovered because of the act)

"If the tree is tainted, the fruit is usually suppressed."

Exceptions to Exclusion

The Bar Exam loves these. These are the ways "tainted" evidence gets back into court.

1. Independent Source

The evidence was found through a completely separate, legal source.

2. Inevitable Discovery

The police would have found the evidence anyway through lawful means (e.g., a grid search already in progress).

3. Attenuation

The link between the illegal act and the evidence is so weak (time, intervening events) that the "taint" is purged.

U.S. v. Leon

4. Good Faith

If police rely on a warrant that is later found invalid, the evidence is NOT suppressed as long as their reliance was objectively reasonable.

Day 3 Quiz: Terry & Exclusion

A police officer pulls over a car for a broken taillight. He has no reason to believe the driver is armed. Can he conduct a pat-down of the driver?