Supreme Court of Delaware

Rashaun J. Miller, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

August 11, 20112011 Del. LEXIS 413

Summary

The Supreme Court of Delaware affirmed the denial of Miller’s motion to suppress and his convictions. It held that the police had reasonable, articulable suspicion to seize Miller because an informant’s detailed predictions about the timing, location, vehicle occupants, and parking maneuver were independently corroborated by police surveillance and contemporaneous confirmation. The court rejected Miller’s reliance on probable-cause cases because the seizure was an investigatory detention rather than an arrest or warrantless vehicle search.