State of Tennessee, Plaintiff-Appellee v. Brian Daniel, Defendant-Appellant

Summary

The Tennessee Supreme Court held that a consensual police-citizen encounter matured into a seizure, under both the Fourth Amendment and Article I, section 7 of the Tennessee Constitution, when the officer retained the defendant's identification to run a computer check for outstanding warrants, because without his identification Daniel was effectively immobilized. Accepting the State's concession that the officer lacked reasonable suspicion, the Court ordered the marijuana disclosed during the arrest search suppressed as fruit of the poisonous tree, reversed the Court of Criminal Appeals, vacated the conviction, and dismissed the charge. Special Justice Byers, joined by Justice Birch, concurred in the result but dissented on the reasoning, contending the seizure occurred at the initial demand for identification absent any reasonable basis.