Michael Holden, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court reversed Holden’s conviction because the police lacked an objectively reasonable, particularized basis to believe that he was armed and dangerous before frisking him. Although the traffic stop was valid and the officers could order passengers out of the vehicle, those circumstances did not independently justify a pat-down, so the firearm had to be suppressed. The court also noted that the trial judge failed to make factual findings or explain the suppression ruling.