State v. Meeker

*83Defendant appeals from a judgment of conviction for possession of heroin, ORS 475.854, and possession of a controlled substance in Schedule III, ORS 475.752(3)(c), assigning error to the trial court's denial of his motion to suppress. Defendant argues that the trial court erred when it determined that the seizure of defendant was justified by the officer safety exception to the warrant requirement under Article I, section 9, of the Oregon Constitution. We agree. The trial court erred in determining that the seizure was justified by the deputy's reasonable suspicion, based on specific and…