State v. Holdorf

An officer who stops a defendant can rely on factual information provided to him by other officers to establish “reasonable suspicion.” An officer’s observation that defendant appeared to be under the influence of methamphetamine, based on the officer’s training and experience, is sufficient to establish “reasonable suspicion” that defendant had committed the crime of possession of methamphetamine.

Defendant was convicted of possession of methamphetamine and appealed the trial courts denial of Defendant’s motion to suppress. Defendant was riding in a car with a known drug dealer. Officers pulled over the vehicle and contacted the driver. Officers noticed Defendant was acting "nervous." After the driver was arrested on a warrant, the officer turned his attention to performing an inventory of the vehicle. Defendant was still seated in the passenger seat when the officer approached and asked if Defendant had any weapons. Defendant answered yes. When the officer opened the door, a knife slid between the seat and the door. The officer then conducted a pat down search finding methamphetamine and marijuana. Defendant argued that officers lacked reasonable suspicion to search him. The state presented the following evidence: 1) the officer’s testimony to the Defendant’s nervousness, 2) the officer’s experience dealing with methamphetamine users, and 3) the officer’s knowledge via another officer that the driver of the vehicle was a known felon with ties to a methamphetamine distribution ring. The Court found that the totality of the circumstances gave rise to a reasonable inference that the Defendant committed the crime of possession of methamphetamine. Court of Appeals decision reversed; trial court decision affirmed.