State of Connecticut v. Christopher Butler

Summary

The court affirmed the defendant’s conviction for possession of narcotics with intent to sell. It held that the warrantless search of the vehicle was a valid protective search because the defendant had not been arrested when the search occurred and the officers had reasonable, articulable suspicion that he was dangerous and might access a weapon. The court also held that the evidence, including the defendant’s movements toward and closure of the console, cash, cell phones, and drug-trafficking circumstances, was sufficient to establish constructive possession beyond a reasonable doubt.