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Court Affirms Denial of Motion to Suppress Based on Reasonable Suspicion Exception

In State of Vermont v. Eric K Manning, 2015 VT 124 (October 2, 2015), the Vermont Supreme Court affirmed the Superior Court’s denial of Defendant’s motion to suppress evidence obtained during a traffic stop.

Issue: The Defendant argued that a prescription pill bottle containing a bag of cocaine seized during a traffic stop was obtained as the result of an unlawful search and seizure and that he was subjected to custodial interrogation without having been read his Miranda rights.

Holding: The Court affirmed the trial court’s rulings but on different grounds from those relied upon below. Specifically, the Court noted that the trial court concluded that the Defendant had not been seized upon exiting his vehicle at the officer’s request. The Court disagreed and determined that a seizure had occurred. However, the Court determined that the officer had grounds for a Terry stop (Terry v. Ohio, 392 U.S. 1(1968)) based upon his reasonable suspicion of criminal activity given the totality of the circumstances. The Court, therefore, affirmed the trial court’s denial of Defendant’s motion to suppress finding the search and seizure reasonable under this exception to traditional Fourth Amendment protections.

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