Swanson v. State

Summary

The Court reversed Swanson’s convictions because police exceeded the permissible scope of an investigative detention when they handcuffed him, transported him to the police station, and detained him for DNA testing. The initial stop was supported by reasonable articulable suspicion, but the transport constituted a de facto arrest that required probable cause, which was absent because police corroborated only Swanson’s identity and location, not his alleged possession of the firearm. The Court did not reach Swanson’s separate challenge to the adequacy of voir dire concerning potential victim bias.