State v. Wilson
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The Supreme Court reversed the decision of the Court of Appeals reversing and vacating Defendant’s conviction of being a felon in possession of a firearm and reversing the trial court’s denial of Defendant’s motion to suppress evidence of the firearm, holding that both the search and seizure of Defendant in this case were supported by individualized suspicion and thus did not violate the Fourth Amendment.
On appeal, the Court of Appeals held that the search was invalid because it was not supported by reasonable suspicion. The Supreme Court reversed, holding (1) the rule announced in Michigan v. Summers, 452 U.S. 692 (1981), justified the seizure because Defendant posed a real threat to the safe and efficient completion of the search; and (2) the warrantless detention and search of Defendant did not violate the Fourth Amendment.
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