State v. Lewis

Summary

The court held that the defendant was not seized until the officer physically touched him, because the earlier questioning and approach did not objectively communicate that he was not free to leave. The seizure and ensuing patdown were nevertheless supported by reasonable and articulable suspicion based on the defendant’s apparent resemblance to a recently reported domestic-violence perpetrator, his close temporal and geographic proximity to the incident, and the violent nature of the reported conduct. The court therefore affirmed the denial of suppression and the judgment of conviction.