State v. Bailey

I disagree with the majority’s determination that the trial court erred when it *1252granted Elaine Bailey’s motion to suppress. The trial court correctly determined that the State did not establish that Officer McCoy had reasonable grounds to believe that Bailey was armed and dangerous and that it was necessary for the protection of the officers and others to conduct a patdown search.

The majority seems to imply that the trial court granted Bailey’s motion to suppress, at least in part, because the court determined that Officer McCoy did not “artfully” state her reasons for conducting the patdown…