Bobby Ray Osborne v. Commonwealth of Kentucky

Summary

The court affirmed the denial of Osborne’s suppression motion, holding that he voluntarily consented to remove items from his pockets during a consensual police encounter. Once Osborne exposed a baggie containing a brown substance, the officers could seize it under the plain-view exception because its incriminating nature was immediately apparent and probable cause existed. The court also held that the trial court’s written findings adequately resolved the suppression issues and that additional findings concerning an investigative detention were unnecessary.