State v. VanBeek
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The Supreme Court reversed the circuit court's judgment of conviction of Defendant for possession of methamphetamine and drug paraphernalia and remanded with instructions to grant Defendant's motion to suppress, holding that the seizure of Defendant was unlawful because the police officer did not have reasonable suspicion that Defendant was engaged in criminal activity.
Defendant's conviction arose from a search of her vehicle. On appeal, Defendant argued that the circuit court erred in denying her motion to suppress because the search violated her Fourth Amendment right to be free from unreasonable searches and seizures. The Supreme Court agreed, holding (1) Defendant was seized when the officer returned to her vehicle after running a records check, withheld her driver's license, and continued to question her and her passenger in order to hold her until a drug-sniff dog arrived; and (2) the seizure was unlawful because Defendant did not have a reasonable suspicion that Defendant was engaged in criminal activity at the time he seized her.
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