Minnesota v. Dickerson
Citation and Court
508 U.S. 366 (1993) — Supreme Court of the United States
Facts
An officer conducted a Terry stop of Dickerson and, during the pat-down frisk for weapons, felt a small lump in his jacket pocket. The officer manipulated the lump with his fingers, concluded it was crack cocaine, and retrieved it. Dickerson moved to suppress the cocaine.
Issue
Whether an officer may seize contraband detected through the sense of touch during a lawful Terry frisk, and if so, whether the search in this case was lawful.
Holding
The “plain feel” doctrine is valid — an officer may seize contraband if its identity is immediately apparent through touch during a lawful frisk — but the search here exceeded those limits because the officer had to manipulate the object to identify it, going beyond the scope of a weapons frisk.
Rule / Doctrine
Plain feel (or plain touch) is a valid analog to the plain view doctrine: if an officer lawfully conducting a pat-down feels an object whose incriminating character is immediately apparent, the officer may seize it without a warrant. However, if the officer must squeeze, slide, or otherwise manipulate the object to identify it as contraband, the search exceeds the scope of a Terry frisk and the evidence must be suppressed.
Significance
Recognized and defined the plain feel doctrine while simultaneously limiting it to cases where contraband is immediately identifiable. Reinforced that Terry frisks are strictly limited to weapons detection and cannot become a pretext for general exploratory searches.