State of West Virginia, Plaintiff Below, Appellee v. John A. Lacy, Defendant Below, Appellant

Summary

The court held that the record was insufficient to determine whether officers lawfully searched for and seized a firearm during execution of a search warrant. It rejected resolving the issue solely under plain view and directed the circuit court to determine whether the officers had specific, articulable, and reasonable grounds to conduct a limited protective weapons search. The court also explained that factual suppression findings receive clear-error review, while the ultimate constitutional reasonableness question is reviewed de novo.