Calm v. State

Summary

The Court held that the passenger's removal from a vehicle after the driver consented to a vehicle search did not, by itself, justify a pat-down. Because the officer lacked reasonable articulable suspicion that the passenger was armed and dangerous when the pat-down began, the firearm and ammunition had to be suppressed, requiring reversal of the related convictions; the resisting-arrest conviction was affirmed because it was unaffected by the suppressed evidence.