Kramer v. State

Kramer appeals from his conviction for tampering with physical evidence, 1 and resisting without violence. 2 He contends that the State’s evidence failed to establish that he was aware that a law enforcement investigation was about to commence when he allegedly swallowed a piece of crack cocaine. We find it unnecessary to address this issue because the trial court should have granted Kramer’s motion for judgment of acquittal where the arresting officer’s testimony established: 1) that the State’s evidence was obtained as the result of an unlawful investigatory stop; and 2) that the officer…