Stopped for Broken Taillight, Restrained & Searched Because of High-Crime Area Late at Night.

May officers, as a matter of standard procedure and in the name of “officer safety,” detain and frisk a driver stopped for an equipment infraction solely on the basis that the stop occurs in a high crime area at night? Here we conclude that the Fourth Amendment does not permit such an intrusion and that any incriminating evidence flowing from the illegal contact, which may include statements made by the driver, is inadmissible.

Roman Medina appeals from the trial court’s denial of his motion to suppress cocaine found on his person and in his vehicle, as well as statements he made to the police at the time of his detention and search. (Pen. Code, § 1538.5.) After the court denied his motion, Medina pleaded guilty to possession of a controlled substance. (Health Saf. Code, § 11350, subd. (a).) Entry of judgment was deferred, and Medina was placed on probation. He contends that the cocaine and the statements attributed to him were obtained in violation of the Fourth Amendment’s prohibition against unreasonable searches and seizures. We agree and, accordingly, reverse.

We reject the People’s claim that the search was prompted by Medina’s admission. Officer Lopez testified that he set out to conduct a patdown pursuant to his “standard procedure,” and his act of securing Medina’s hands behind his head was part and parcel of that search. We also agree with Medina that his detention was rendered unlawful when Officer Lopez grabbed his hands, and that the ensuing search was also illegal because the officer failed to offer articulable facts demonstrating a reasonable suspicion that Medina was armed and dangerous. Indeed, the officer admitted there were no such facts. The only reason for restraining Medina’s hands and searching him was the time and location of the stop. Apparently, anyone observed to be driving in that area at night with a citable equipment defect would be stopped and subjected to a patdown search. The Fourth Amendment plainly prohibits the police from employing such a procedure.

Read the full case here: People v. Medina, 110 Cal.App.4th 171 (Cal. Ct. App. 2003), https://casetext.com/case/people-v-medina-299