Andre Williamsv.The State
After an unidentified source reported drug activity at an Augusta hotel, officers watched a man enter and leave a room, approach Andre Williams in the hotel breezeway, retain his room key, and question him about drugs. Williams acknowledged marijuana in his room; officers then handcuffed and searched him, finding cocaine, marijuana, and cash. A bench trial resulted in convictions for trafficking cocaine and possessing marijuana. The Court of Appeals of Georgia held that the officers lacked reasonable articulable suspicion for the second-tier encounter that led to the search. The anonymous information did not predict future conduct or contain reliable inside details, and the officers observed no drug transaction, possession, or other violation to corroborate it. The court reversed the denial of Williams’s motion for a new trial, requiring suppression of the evidence obtained after the unlawful detention.
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