Missouri Court of Appeals, Eastern District / Apr 28, 2020
State of Missouri, Appellant, vs. Jeffrey Randall Lindsay, Respondent.
The State of Missouri appealed the trial court's order granting Jeffrey Randall Lindsay's motion to suppress evidence obtained from a warrantless vehicle search, which formed the basis for drug charges. The trial court suppressed the evidence, finding the officer lacked reasonable suspicion of illegal drugs. The Eastern District reversed, holding that while the officer lacked suspicion for a drug search, his concern for personal safety, based on Lindsay being classified as "Caution 1" and the vehicle's clutter, justified a protective search for weapons in the same areas where the drugs were found.