STATE OF LOUISIANA v. ARTHUR COLEMAN (2025)

Relator, the State of Louisiana (“the State”), seeks supervisory review of the trial court's August 8, 2025 ruling, which granted the motion to suppress statements and evidence filed by Respondent-Defendant, Arthur Coleman (“Defendant”). For the following reasons, we grant the writ application and reverse the trial court's ruling.

FACTUAL AND PROCEDURAL HISTORY

On April 10, 2025, Defendant was charged via bill of information with carrying a firearm by a student or nonstudent on school property, at school-sponsored functions, or in a firearm-free zone in violation of La. R.S. 14:95.2.

Defendant filed a motion for suppression of statements and evidence on the grounds that the information was obtained via an illegal stop and frisk and illegal interrogation on July 10, 2025. The same date, the trial court heard testimony from Trooper Tyler Laiche (“Trooper Laiche”).

Trooper Laiche testified that he and about four troopers were on patrol along an active parade route on St. Charles Avenue. He stated on St. Charles Avenue and Polymnia Street, the officers observed three men “walking shoulder to shoulder” and one of the individuals (not Defendant) was smoking marijuana. Trooper Laiche testified they detained the individuals and asked if anyone had any weapons on them. Trooper Laiche explained that he asked the men whether they were in possession of a weapon due to officer safety. Defendant admitted he had a gun. Trooper Laiche stated that they then walked towards the sidewalk and he retrieved the firearm from the Defendant's backpack.¹ Defendant was thereafter Mirandized. Defendant admitted the gun was his and stated that he was unaware he could not have a firearm on the parade route. Defendant was subsequently arrested.

Following the hearing, the trial court took the matter under advisement and permitted additional briefing. The State filed an opposition to the motion to suppress on July 21, 2025. Defendant filed his supplemental brief on July 25, 2025.

On August 8, 2025, the trial court issued a ruling, which granted the motion to suppress. The trial court reasoned, in part:

[The] troopers did not have reasonable suspicion to stop Mr. Coleman [Defendant]. Although a person near Mr. Coleman was visibly smoking what troopers suspected was a marijuana cigarette, Trooper Laiche could not point out any illicit activity that Mr. Coleman himself was engaged in. Unlike in State v. Jackson, where the officers had reasonable suspicion to detain the defendant because the group smelled of marijuana, here, [the] troopers did not specify any reason why they suspected Mr. Coleman particularly of criminal activity. Because [the] troopers did not have reasonable suspicion to detain Mr. Coleman, his statements and the evidence seized against him must be suppressed as fruit of the poisonous tree.

The State filed its writ application seeking review of the trial court's ruling with expedited consideration on August 21, 2025. The same date, this Court ordered Defendant to file a response and the trial court to issue a per curiam by August 22, 2025 by 3:00 p.m.

On August, 22, 2025, Defendant filed a motion for extension of time and a motion to strike the State's request for expedited consideration and for sanctions. This Court granted Defendant until noon August 27, 2025 to file his response and denied the motion to strike and for sanctions.

The trial court filed its per curiam on August 22, 2025. Defendant timely filed his opposition to the writ application on August 27, 2025.

APPLICABLE LAW AND DISCUSSION

This Court in State v. Debose, 2024-0217, pp. 6-7 (La. App. 4 Cir. 6/13/24), 390 So.3d 971, 977, outlined the standard of review on the trial court's ruling on a motion to suppress as follows:

District courts have great discretion when ruling on motions to suppress, and an appellate court will not disturb a district court's ruling on a motion to suppress unless the district court abused its discretion. State v. Willis, 2022-0452, pp. 6-7 (La. App. 4 Cir. 9/1/22), 348 So.3d 167, 172 (quoting State v. Polkey, 2020-0482, p. 3 (La. App. 4 Cir. 11/25/20), 310 So.3d 605, 608). The reason the district court's decision “on a motion to suppress ․ is entitled to great weight” is “because the [district] court has the opportunity to observe the witnesses and weigh the credibility of their testimony.” Id. at p. 7, 348 So.3d at 172 (alteration in original) (quoting State ex rel. J.S., 2008-1401, p. 4 (La. App. 4 Cir. 2/18/09), 6 So.3d 904, 908). As this Court has previously explained though, “a motion to suppress presents a mixed question of law and fact.” Id. (citing Polkey, 2020-0482, p. 4, 310 So.3d at 608). Thus, the appellate court reviews the underlying facts for an abuse of discretion “but reviews conclusions to be drawn from those facts de novo.” Id. When the facts are not disputed, however, then the appellate court need only “consider whether the trial court came to the proper legal determination under the undisputed facts.” Id.

La. C.Cr.P. art. 215.1 (A) provides: “[a] law enforcement officer may stop a person in a public place whom he reasonably suspects is committing, has committed, or is about to commit an offense and may demand of him his name, address, and an explanation of his actions.” See also Terry v. Ohio, 392 U.S. 1, 30, 88 S.Ct. 1868, 1884-85, 20 L.Ed.2d 889 (1968).

“The reasonable suspicion standard required for an investigatory stop ‘is considerably less than proof of wrongdoing by a preponderance of the evidence.’ ” State v. Ardoin, 2025-0084, p. 5 (La. App. 4 Cir. 2/26/25), 409 So.3d 1018, 1022 (quoting United States v. Sokolow, 490 U.S. 1, 7, 109 S.Ct. 1581, 1585, 104 L.Ed.2d 1 (1989)).

In assessing the reasonableness of an investigatory stop, the court must balance the need for the stop against the invasion of privacy it entails and consider the totality of the circumstances in determining whether reasonable suspicion exists. The detaining officers must have knowledge of specific articulable facts, which, if taken together with rational inferences from those facts, warrant the stop. The officer's past experience, training and common sense may be considered in determining if his inferences from the facts at hand were reasonable, and deference should be given to the experience of the officers present at the time of the incident.

Id. (quoting State v. Marzett, 2009-1080, pp. 5-6 (La. App. 4 Cir. 6/9/10), 40 So.3d 1204, 1208 (internal citation omitted)).

Here, we find that under the totality of circumstances, including the presence of contraband in plain view, and the group's shared movement, that the troopers had reasonable suspicion to conduct an investigatory stop of all members of the group, including Defendant. Moreover, the trial court's reliance on the absence of the troopers’ direct observation of Defendant smoking is misplaced. Reasonable suspicion does not require proof of personal possession; it requires an articulable, objective basis to suspect involvement in criminal activity. Given the immediate proximity, association, and circumstances, we find that the troopers had reasonable suspicion to justify the investigatory stop of Defendant. As such, we find that the trial court erred in granting the motion to suppress. We therefore grant the writ application and reverse the trial court's ruling.

WRIT GRANTED AND REVERSED

FOOTNOTES

1.   Trooper Laiche identified body camera video of the encounter; a city ordinance outlining the parade routes; a map of uptown parade routes; and a photograph of Defendant's firearm, which were then admitted into evidence.

Judge Karen K. Herman

JENKINS, J., DISSENTS AND ASSIGNS REASONS