Supreme Court of Delaware

Womack v. State

April 24, 2023

Summary

The Court affirmed the denial of Womack’s motion to suppress evidence seized after he fled during a vehicle search. It held that the officers’ attempt to handcuff Womack did not convert his lawful investigative detention into an arrest because the totality of the circumstances supported using handcuffs to control the evolving scene. Womack’s flight created probable cause for his arrest, after which the discarded backpack could be searched. The opinion also held that Womack waived any distinct state constitutional argument by failing to develop it.