State v. Hollins

Observations by an officer, with articulable, relevant training and experience of a hand-to-hand transaction near a "hot spot" for drug and weapon activity objectively support reasonable suspicion. State v. Walker, 277 Or App. 397, 402, 372 P3d 540, rev den, 360 Or 423 (2016).

Defendant appealed a conditional guilty plea to felon in possession of a restricted weapon. Defendant assigned error to the trial court's denial of his motion to suppress evidence obtained during a consent search. On appeal, Defendant argued that the officer lacked reasonable suspicion to initiate the stop that led to his consent. In response, the State argued that the officer's actions were supported by reasonable suspicion. Alternatively, the State argued that reasonable suspicion was not required because the encounter was not a seizure as a matter of law. Observations by an officer, with articulable, relevant training and experience of a hand-to-hand transaction near a "hot spot" for drug and weapon activity objectively support reasonable suspicion. State v. Walker, 277 Or App. 397, 402, 372 P3d 540, rev den, 360 Or 423 (2016). The Court held that the officer's observations of Defendant engaged in hand-to-hand transactions in an area known for drug and weapon activity, coupled with the officer's experience on a gang task force, objectively supported his reasonable suspicion to seize Defendant. Affirmed.