State v. Kelly

Summary

The court held that the Connecticut Constitution permits police to briefly detain a suspect's companion as a protective measure when the suspect has been lawfully detained and officers reasonably believe the suspect poses a threat to their safety, even without individualized suspicion that the companion committed a crime. The court concluded that the officers' safety concerns and the limited nature of the detention justified the stop and that the cocaine was not subject to suppression. The defendant's challenge to the factual basis for the stop was moot because the trial court's subsequent articulation clarified and supported the relevant findings.