Baldwin v. State

KELLER, PJ.,

delivered the opinion of the unanimous court.

The question here is whether an officer exceeded his authority during a suspect’s detention. After asking the handcuffed suspect where his identification was located, the officer reached into the suspect’s pocket to retrieve his wallet. We hold that the officer did exceed his authority, and we reverse the judgments of the courts below.

I. BACKGROUND

A. The Incident

The trial court denied appellant’s motion to suppress evidence without making any express findings of fact. Viewed in the light most favorable to the trial court’s ruling,1 the…