Supreme Court of Delaware
Ron Flowers, Defendant-Below, Appellant v. State of Delaware, Plaintiff-Below, Appellee.
September 27, 2018195 A.3d 18
Summary
The Supreme Court of Delaware affirmed the denial of Flowers's motion to suppress the firearm discovered during a police stop and frisk. The officers had reasonable, articulable suspicion based on Flowers's movements, the apparent object in his waistband, the late hour, and the high-crime location, and ordering him to the ground was a reasonable protective measure that did not convert the stop into an arrest. The court also held that any challenge to reliance on the tip was waived and, in any event, the officers' independent observations sufficiently justified the seizure.