State v. Edmonds

Summary

The court held that the defendant was seized no later than when an armed, uniformed officer commanded him to stop after two marked police cruisers converged on him in a small private parking lot. The officers lacked reasonable and articulable suspicion because the defendant's presence in a high-crime area, brief movement away from police, and hand movement near his waistband did not sufficiently indicate criminal activity. The court also held that the seizure-timing claim was preserved and reviewable on the existing record, reversed the Appellate Court, and directed suppression of the narcotics evidence.