Cited by

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).

“When probable cause exists to believe that a vehicle contains contraband, the Fourth Amendment permits th e police to search the vehicle without a warrant.” (Mi nn.

State v. Flowers , (Mi nn.

at 363; d 239, 266 n.36 (Minn. 2007) (Gildea, J., concurring in part, dissenting in part) (noting that the permissible scope of a Terry stop is “a concept that is drawn from the federal constitution”).

When articulating reasonable suspicion, officers are permitted to rely on “inferences and deductions that might well elude an untrained person.” -52 (Minn. 2007).

“[T]he police may stop and frisk a person when (1) they have a reasonable, articulable suspicion that a suspect might be engaged in criminal activity and (2) the officer reasonably believes the suspect might be armed and dangerous.” (quotation omitted).

See Childs, d at 27; – 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)).

State v. Flowers , , 248 (Minn. 2007) .

State v. Flowers , , 252 (Minn. 2007).

the supreme court recognized that furtive movements of a driver during a routine traffic stop may give rise to a reasonable belief that the driver is armed and dangerous and, thus, may justify measures to restrain the driver.

(quotations omitted); -52 (Minn. 2007) (noting that police officers may use their special training to “make inferences and 7 deductions that might well elude an untrained person”), Britton , d at 88-89 (stating that “[w]e are deferential to police officer training and experience”).

Probable cause exists “when a person of ordinary care and prudence, viewing the totality of circumstances objectively, would entertain an honest and strong suspicion that a specific individual has committed a crime.” (-48 (Minn. 2007)).

d 239, 253 (Minn. 2007), supports the reasonableness of the pat search.

(“[W]e have concluded that Flowers’ rights under our state constitution were violated, and therefore we need not address the issue of whether Flowers’ rights under the federal constitution were violated.”).

United States v. Ross, 456 U.S. 798, 806 n.8, 102 S. Ct. 2157, 2163 n.8 (1982); State v. Flowers

“[I]n the absence of probable cause, the police may stop and frisk a person when (1) they have a reasonable articulable suspicion that a suspect might be engaged in criminal activity and (2) the officer reasonably believes that suspect might be armed and dangerous.” -51 (Minn. 2007) (summarizing holding of Terry, 392 U.S. 1, 88 S. Ct. 1868).

See State v. Flowers , –51 (Minn. 2007) (“ 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.”).

State v. Flowers , (“[T]he search is unreasonable unless the state proves that the search fell within one of the exceptions to the warrant requirement.”).

When determining whether reasonable, articulable suspicion exists, appellate courts consider the totality of the circumstances, including that police officers’ specialized training may allow them to “make inferences or deductions that might elude an untrained person.” - 52 (Minn. 2007).

Finally, “by virtue of the special training they receive, police officers articulating a reasonable suspicion may make inferences and deductions that might well elude an 6 untrained person.” State v. Flowers , -52 (Minn. 2007) (citing Askerooth, d at 369)).

To be constitutional, “each incremental intrusion” during a stop must be connected to and justified by: “(1) the original legitimate purpose of the stop, (2) independent probable cause, or (3) reasonableness, as defined in Terry [v. Ohio, 392 U.S. 1, 30, 88 S. Ct. 1868, 1884 (1968)].” (summarizing holding in Terry as “even in the absence of probable cause, the police may stop and frisk a person 7 when (1) they have a reasonable, articulable suspicion that a suspect might be engaged in criminal a

Under Terry, the “police may stop and frisk a person when (1) they have a reasonable, articulable suspicion that a suspect might be engaged in criminal activity and (2) the officer reasonably believes the suspect might be armed and dangerous.” 4 (citing Terry v. Ohio, 392 U.S. 1, 30, 88 S. Ct. 1868, 1884 (1968)) (other 3 Heiderscheid contends Timberlake “is inapposite here” because the 911 caller did not personally see him with the gun, and therefore, Timberlake is distinguishable.

4 D E C I S I O N “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)).

(stating that the automobile exception allows officers to search a car without a warrant if they have probable cause to believe the car contains contraband).

The supreme court has summarized Terry as follows: “[E]ven in the absence of probable cause, the police may stop and frisk a person when (1) they have a reasonable, articulable suspicion that a suspect might be engaged in criminal activity and (2) the officer re asonably believes the suspect might be armed and dangerous.” State v. Flowers , (quotations omitted); accord Terry v. Ohio, 392 U.S. 1, 30, 88 S. Ct. 1868, 1884 (1968).

“A search conducted without a warrant issued upon probable cause is generally unreasonable” unless “the state proves that the search fell within one of the exceptions to the warrant requirement.”

Moreover, “[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.” State v. Flowers