Cited by

See Leonard, d at 152 n.1; d 239, 258 (Minn. 2007).

An officer may conduct a “protective search” of a vehicle if the officer has a “particularized and objective basis for suspecting the particular person stopped of criminal activity” and the officer “possesses a reasonable belief, based on specific and articulable facts, that the suspect is dangerous and may gain immediate control of a weapon.” (quotation omitted).

to support her argument that the deputy lacked probable cause to search her vehicle.

When the facts are not in dispute, as here, appellate courts “review a pretrial order on a motion to suppress evidence de novo and ‘determine whether the police articulated an adequate basis for the search or seizure at issue.’” ().

252 (Minn. 2007) (concluding that driver’s actions including lunging toward the passenger door, leaning fully into the passenger’s seat, and slamming his hand on the 13 driver’s door panel as if he was trying to pull it apart constituted furtive movements suppor

If the facts are not disputed on appeal, the pretrial order is reviewed de novo to “determine whether the police articulated an adequate basis for the search or seizure at issue.” -48 (Minn. 2007).

Under the automobile exception to the warrant requirement, “[w]hen probable cause exists to believe that a vehicle contains contraband, the Fourth Amendment permits the police to search the vehicle without a warrant.”

(recognizing that probable cause can support a vehicle search under the vehicle exception to the warrant requirement).

d 239, 251-52 (Minn. 2007).

d of up, down, side to side,” and specifically noted that he “reach[ed] to the right side.” The officer testified 1 “A Terry stop permits an officer who suspects that an individual is engaged in illegal activity and also believes that a suspect may be armed and dangerous to frisk the suspect in order to reduce concerns that the suspect poses a danger to officer safety.” -51 (Minn. 2007) (citing Terry v. Ohio, 392 U.S. 1 (1968)).

“The state has the burden to prove that, in the absence of a search warrant,” police had “probable cause to conduct a search.”

Terry v. Ohio, 392 U.S. 1, 30-31 (1968).

(determining that “suspicious movements” lasting approximately 45 seconds justified a reasonable suspicion that a vehicle’s occupant was “involved in some type of criminal activity and that he might have been armed and dangerous”); (noting tha

(citing Maryland v. Dyson, 527 U.S. 465, 467 (1999)).

8 allows them to make inferences about physical symptoms that may elude lay observers); (noting officers may consider “the erratic behavior of or suspicious movements by the persons under observation” to establish reasonable suspicion); Lugo, d at 487 (stating even arrests that do not lead to convictions can be considered to establish reasonable suspicion if they were for of

(“When probable cause exists to believe that a vehicle contains contraband, the Fourth Amendment permits the police to search the vehicle without a warrant.”); (“Upon observing evidence in plain view, a warrantless search of the remainder of t

“A Terry stop permits an officer who suspects that an individual is engaged in illegal activity and also believes that a suspect may be armed and dangerous to frisk the suspect in order to reduce concerns that the suspect poses a danger to officer safety.” -51 (Minn. 2007).

We must determine “whether the police articulated an adequate basis for the search or seizure at issue.”

.’” (quoting Adams v. Williams, 407 U.S. 143, 146 (1972)).

(“When the facts are not in dispute, our review is de novo, and we must determine whether the police articulated an adequate basis for the search or seizure at issue.”).

ce and significance of the objective facts independently before considering them in their totality); Burbach, d at 489-91 (concluding that police did not have reasonable suspicion of drug possession justifying a search of appellant’s vehicle and stating that “[e]ach of these factors is weak evidence of drug possession, and they are also weak in the aggregate”); (noting that “while the officers had their suspicions, the strength of their suspicions was not great”).

The “reasonableness inquiry considers the ‘totality of the circumstances,’ including the special training, experience, and ability of law enforcement officers to make inferences and deductions beyond that of the average person.” -39 (Minn. 2021) (-52 (Minn. 2007)).

When the facts underlying a pretrial order on a motion to suppress are not in dispute, we review de novo “whether the police articulated an adequate basis for the search or seizure at issue.” - 48 (Minn. 2007); d 366, 369 (Minn. App. 2018).

Additionally, appellate courts have noted that “by virtue of the special training they receive, police officers articulating a reasonable suspicion may make inferences and deductions that might well elude an untrained person.” (- 52 (Minn. 2007)).

“When facts are not in dispute, as here, we review a pretrial order on a motion to suppress de novo and ‘determine whether the police articulated an adequate basis for the search or seizure at issue.’” (-48 (Minn. 2007)).

at 754 (stating that officer’s knowledge that driver’s license was canceled as inimical to public safety contributed to reasonable suspicion of impaired driving); (stating that knowledge of a suspect’s criminal record may contribute to probable cause).