State v. Thomas

Defendant conditionally pleaded guilty to two counts of unlawful possession of a firearm, in violation of ORS 166.272 (Count 1) and ORS 166.250 (Count 2), reserving the right to appeal the trial court’s denial of his motion to suppress the evidence of the short-barreled shotgun that he possessed. On appeal, defendant assigns error to the trial court’s denial of his motion to suppress. He argues that the trial court erred when it determined that the war-rantless patdown of defendant that led to the discovery of the gun was justified by the “officer-safety” exception to the warrant requirement…