Page 40 - TPA Journal January February 2025

Transportation Code § 545.058. been described by the dealer as a heavyset Black
male with yellow or blond dreadlocks who drove
As to the second part, the district court stated the a black sports car. Papanos conveyed his suspicion
continuance of the traffic stop was justified to Brown, who prolonged the stop on the basis of
because Henry drove with a suspended license and reasonable suspicion.
was a suspect in an ongoing drug trafficking
investigation. We agree. A detention must be tem- The CID agents’ discovery of Meagan Green’s
porary and last no longer than is necessary to bond paperwork strengthened this suspicion.
effectuate the purpose of the stop, unless further Brown made permissible “commonsense judg-
reasonable suspicion, supported by articulable ments and inferences about human behavior” and
facts, emerges. The question before this Court, his own policing experiences. Brown’s suspicion
then, is whether Brown’s actions after he stopped that Henry was a drug dealer known as Casper was
Henry and before the heroin was found were rea- reasonable under the Fourth Amendment. Agent
sonably related to the circumstances that justified Papanos was involved in an ongoing heroin traf-
the stop, or to dispelling his reasonable suspicion ficking investigation. Two days earlier, he arrested
developed during the stop. Approximately three Meagan Green after she delivered heroin that had
minutes into the stop, Brown found that Henry’s been ordered by a cooperating street dealer from
license was suspended. There is no constitutional his supplier, whom he knew only as Casper.
impediment to a law enforcement officer’s request Papanos was on the lookout for Casper, who had
to examine a driver’s license during a traffic stop been described by the dealer as a heavyset Black
and run a computer check. At this point, Brown male with yellow or blond dreadlocks who drove
could have arrested Henry for driving with a sus- a black sports car. Papanos conveyed his suspicion
pended license. Moreover, Brown developed rea- to Brown, who prolonged the stop on the basis of
sonable suspicion that Henry was involved in the reasonable suspicion.
sale of heroin as the stop progressed—Papanos
explained to him that Henry matched the descrip- The CID agents’ discovery of Meagan Green’s
tion of a drug trafficking suspect. bond paperwork strengthened this suspicion.
Brown made permissible “commonsense judg-
The “touchstone of Fourth Amendment analysis is ments and inferences about human behavior” and
reasonableness.” Reasonableness requires a bal- his own policing experiences. Brown’s suspicion
ancing of the public interest with an individual’s that Henry was a drug dealer known as Casper was
right to be free from arbitrary intrusions by law reasonable under the Fourth Amendment. Agent
enforcement. The Supreme Court has emphasized Papanos was involved in an ongoing heroin traf-
that courts must allow “officers to draw on their ficking investigation. Two days earlier, he arrested
own experience and specialized training to make Meagan Green after she delivered heroin that had
inferences from and deductions about the cumula- been ordered by a cooperating street dealer from
tive information available to them that ‘might well his supplier, whom he knew only as Casper.
elude an untrained person.’” Brown’s suspicion Papanos was on the lookout for Casper, who had
that Henry was a drug dealer known as Casper was been described by the dealer as a heavyset Black
reasonable under the Fourth Amendment. Agent male with yellow or blond dreadlocks who drove
Papanos was involved in an ongoing heroin traf- a black sports car. Papanos conveyed his suspicion
ficking investigation. Two days earlier, he arrested to Brown, who prolonged the stop on the basis of
Meagan Green after she delivered heroin that had reasonable suspicion.
been ordered by a cooperating street dealer from
his supplier, whom he knew only as Casper. The CID agents’ discovery of Meagan Green’s
Papanos was on the lookout for Casper, who had bond paperwork strengthened this suspicion.

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