Running head: MINNESOTA v.
1
Minnesota v. Dickerson, 508 U.S. 366 (1993): Case Brief Summary
Rochelle Burks
Grand Canyon University: JUS 635-O101
July 15, 2014
MINNESOTA v.
2
Minnesota v. Dickerson, 508 U.S. 366 (1993)
JUDICIAL HISTORY
Dickerson moved to suppress the cocaine found in his possession. The trial court concluded the
officers were justified in stopping and frisking him to investigate whether he might be engaged
in criminal activity and/or carrying a weapon. The court also concluded that the contraband
(cocaine) seized during the frisking did not violate the respondent’s Fourth Amendment rights.
His motion was denied. Dickerson proceeded to trial and was found guilty. However, on appeal,
the Minnesota Court of Appeals reversed the trial court’s decision, and the State Supreme Court
affirmed. The U.S. Supreme Court granted certiorari.
FACTS
Dickerson was observed leaving a 12-unit apartment building, believed to be a neighborhood
“crack house,” on Morgan Avenue North at approximately 8:15 p.m. Upon seeing a police squad
car and making eye contact with one of the officers, Dickerson stopped abruptly and proceeded
to walk in the opposite direction, turning down an alley on the other side of the apartment
building, which sparked the officers’ suspicion. The officers stopped him and he submitted to a
“patdown” search. Although the search did not produce any weapons, the officer felt what was
believed to be drugs in Dickerson’s front pocket. The officer reached into Dickerson’s pocket
and extracted 1/5 of a gram of crack cocaine in cellophane wrapping. He was arrested and
charged with possession of a controlled substance.
ISSUES
1. Were Dickerson’s rights under the Fourth Amendment violated when, during a protective
patdown search, contraband (cocaine) was seized that was detected by a police officer’s
sense of touch?
2. Was the officer who conducted the search acting within the lawful bounds marked by
Terry v. Ohio, 392 U.S. 1, 20 L. Ed. 2d 889, 88 S. Ct. 1868 (1968), at the time he gained
probable cause to believe that the lump in Dickerson’s jacket was contraband?
MINNESOTA v.
3
RULES
Fourth Amendment: “guarantees the right of the people to be secure in their persons, houses,
papers, and effects against unreasonable searches and seizures.”
Terry v. Ohio, 392 U.S. 1, 20 L. Ed. 2d 889, 88 S. Ct. 1868 (1968): “where a police officer
observes unusual conduct which leads him reasonably to conclude in light of his experience that
criminal activity may be afoot…,” the officer may briefly stop the suspicious person and make
“reasonable inquiries” aimed at confirming or dispelling his suspicions and, if believed the
person is armed and dangerous, to determine whether or not the person is in fact carrying a
weapon.”
Sibron v. NewYork, 392 U.S. 40, 65-66, 20 L. Ed. 2d 917, 88 S. Ct. 1889 (1968): “If the
protective search goes beyond what is necessary to determine if the suspect is armed, it is no
longer valid under Terry and its fruits will be suppressed.”
Arizona v. Hicks, 480 U.S. 321, 94 L. Ed. 2d 347, 107 S. Ct. 1149 (1987): Police require
probable cause to seize items in plain view (touch, allowed by Terry in patdowns, that does not
render immediate apparency of incriminating character does not apply as plain view.)
ANALYSIS
The Terry case permits a brief stop of a person whose suspicious conduct leads an officer to
conclude, in light of his experience, that criminal activity may be occurring, and a patdown
search of the person for weapons when the officer is justified in believing that the person may be
armed and presently dangerous. Mr. Dickerson’s stop and frisk was not outside the scope of
Terry because he was seen leaving a building known for drug trafficking; thus, it was not
unreasonable to believe that he may be in possession of a weapon. During the patdown, the
officer conducting the search immediately ascertained that Mr. Dickerson had no weapons but
continued the search after feeling a lump in the front pocket of his jacket. The lump the officer
felt was only deemed as contraband after continuous probing and manipulation of the object in
Mr. Dickerson’s pocket, which invalidates the plain view doctrine and oversteps the bounds
allowed by Terry. In fact, by the officers own admission, he determined the lump as contraband
by “squeezing, sliding, and otherwise manipulating the contents of the defendant’s pocket,” a
MINNESOTA v.
4
pocket the officer knew was weaponless. The protective search allowed by Terry, permitted
without a warrant and on the basis of reasonable suspicion less than probable cause, is not meant
to discover evidence of a crime, but must be strictly limited to that which is necessary for
discovery of weapons which might be used to harm the officer or others. The Court agrees that
the officers were justified in frisking Mr. Dickerson to ensure that he was not carrying a weapon.
However, the officer’s continued exploration of Mr. Dickerson’s pocket after it was apparent that
it did not contain a weapon was unrelated to the justification of a search provided by Terry, and
therefore, constitutionally invalid. Consequently, the seizure of the cocaine that followed was
unconstitutional as well.
CONCLUSION
Although the officer was lawfully permitted to stop and frisk Mr. Dickerson, it was not the
opinion of the Court that the continuous probing was justified once it was apparent that no
weapons existed on Mr. Dickerson’s person. Therefore, a further search of Mr. Dickerson
pockets and the contents seized therein were both deemed constitutionally invalid. The judgment
of the Minnesota Supreme Court was affirmed.