STATE OF LOUISIANA v. ALONZO WILLIAMS (2026)

Relator, the State of Louisiana (the “State”), seeks review of the district court's April 15, 2026 ruling, which granted Alonzo Williams’ (“Respondent”) motion to suppress all evidence and statements arising from his June 20, 2025 arrest. For the following reasons, we grant the State's writ, reverse the district court's ruling and remand this matter to the district court for further proceedings consistent with this writ opinion.

FACTUAL AND PROCEDURAL HISTORY

On August 26, 2025, the State filed a bill of information charging Respondent with one count each of possession of marijuana with intent to distribute; possession of Tapentadol; possession of drug paraphernalia; and violation of vehicle registration provisions. On September 26, 2025, Respondent entered pleas of not guilty to all charges. On November 4, 2025, Respondent filed a particularized motion to suppress evidence and statements, which he supplemented on January 16, 2026. The district court held a motions hearing on February 25, 2026.

At the hearing, Louisiana State Trooper William Stogner (“Ofc. Stogner”) testified, and his body camera footage was played before the court. According to Ofc. Stogner, in the late evening hours on June 20, 2025, he conducted a traffic stop, assisted by other officers, after discovering that Respondent's license plate was registered to a different vehicle. As Respondent exited the vehicle and began to engage in conversation with Ofc. Stogner, he began crumbling up something in his hand and pieces of white particles fell to the ground. When Ofc. Stogner reached down to recover it, he discovered it was a white pill that Respondent subsequently identified as “Tramadol.”¹ Shortly thereafter, Ofc. Stogner detained Respondent in handcuffs and issued Miranda warnings. While Respondent was detained, Sergeant Cameron Crockett (“Sgt. Crockett”) observed him removing a bundle of clear plastic sandwich bags from his right, back pocket. At this time, Officer Calvin Wynn (“Ofc. Wynn”) proceeded to retrieve Respondent's driver's license from the vehicle to identify him.

Ofc. Stogner testified that when Ofc. Wynn retrieved the license from Respondent's vehicle, Ofc. Wynn stated that he smelled marijuana.² Ofcs. Stogner and Wynn proceeded to conduct a warrantless search of Respondent's vehicle and located two digital scales and a clear Ziplock bag that had individually packaged marijuana in it that weighed eighty grams in total. Ofc. Stogner testified that several of the baggies had their corners removed, which was indicative of packaging small amounts of narcotics.

Following the hearing, the district court ordered the parties to submit post-hearing memoranda; the parties filed their respective memoranda on March 13, 2026. On April 15, 2026, the district court issued a written ruling, finding unconstitutional the warrantless search of Respondent's vehicle. The district court suppressed all evidence seized therefrom and all of Respondent's statements made after the search of the vehicle began as fruit of the poisonous tree.³

DISCUSSION

This Court has previously held that “[a] district court has ‘great discretion when ruling on a motion to suppress[,]’ and the district court's ruling ‘will not be disturbed absent an abuse of that discretion.’ ” State v. Olvarrieta 25-0403, p. 3 (La. App. 4 Cir. 8/8/25), 418 So.3d 546, 549 (citations omitted). “However, a motion to suppress presents a mixed question of law and fact.” Id. “Accordingly, an ‘appellate court reviews the underlying facts [under] an abuse of discretion standard, but reviews conclusions to be drawn from those facts de novo.’ ” Id. at p. 3, 418 So.3d at 549.

In this writ, the State asserts that the district court erred in granting Respondent's motion to suppress evidence in part, and in finding that no exception to the Fourth Amendment warrant requirement was applicable in the instant circumstances, notwithstanding its contemporaneous finding that officers possessed probable cause to arrest Respondent for the possession of (and attempt to destroy) narcotics in his pocket.⁴ The State further argues that because the search of Respondent's vehicle was legal, his subsequent statements should not have been suppressed as fruit of the poisonous tree.

In opposition, Respondent maintains that Ofc. Stogner did not know for certain that the pill Respondent started to crumble was a controlled substance when he initiated the search of his vehicle. Thus, Respondent's actions in evasively concealing the pill in his fist and crumbling it could not constitute probable cause to search the vehicle for contraband. We disagree and find the Louisiana Supreme Court case of State v. Crawford to be analogous to the facts of this case. 17-0025 (La. 2/24/27), 210 So.3d 268.

In Crawford, while attempting to stop the defendant for a traffic violation, the arresting officer observed the defendant discard a plastic bag. After arresting the defendant, the officer found the dry empty bag and testified that in his experience “when people are throwing things out of a car when you are pursuing them, they are usually trying to discard some sort of drugs.” Id. at p. 2, 210 So.3d at 269. He further testified that “he had often dealt with narcotics in that fashion, tied in a plastic bag.” Id. The Supreme Court reasoned that

Here, the arresting officer, while attempting to stop the defendant for a traffic violation, observed the defendant attempt evasive actions, saw the defendant discard the bag, and then subsequently found the dry empty bag along the road about where he had seen the defendant toss it out the window. These circumstances, combined with the arresting officer's experience in the field, provided a reasonable basis on which to believe that the bag and the defendant's actions were consistent with drug trafficking. Thus, the officer had sufficient probable cause to search the vehicle under the automobile exception described in [United States v.] Ross.5

Id. at pp. 3-4, 210 So.3d at 270. See Ross, 456 U.S. 798, 824-825, 102 S. Ct. 2157, 2172-2173, 72 L. Ed. 2d 572 (1982).

In the case sub judice, Respondent also attempted evasive conduct by crumbling a pill in his hand and attempting to remove a bundle of clear plastic sandwich bags from his back pocket while handcuffed. Ofc. Stogner testified that, based on his experience, “if someone did have narcotics on them, it is very common for them to put it in a bag and put it in the corner of the bag and tie it.” He further testified that “several corners had been pulled off the bags, but there was nothing in them,” indicating that the bags would later be used for packaging small amounts of narcotics. Based on our review, we find the facts of this case provided a reasonable basis to believe that the bags paired with Respondent's action to crumble up a narcotic pill were consistent with drug trafficking. As such, the officers had sufficient probable cause to search the vehicle under the automobile exception.

CONCLUSION

For the foregoing reasons, the State's writ is granted, the district court's April 15, 2026 ruling is reversed, and the matter is remanded to the district court for further proceedings consistent with this writ opinion.

WRIT GRANTED; REVERSED AND REMANED

FOOTNOTES

1.   The pill was later discovered to be Tapentadol, a narcotic.

2.   In the district court's written ruling, it found that Ofc. Stogner's assertion that Ofc. Wynn detected the odor of marijuana prior to searching the vehicle was not credible. The district court explained that “[t]he record reflects no contemporaneous mention of marijuana odor at the time of the initial stop, removal of Mr. Williams from the vehicle, or during the frisk.” Moreover, the court stated that “the troopers did not exhibit any immediate physical or verbal reaction consistent with the detection of a strong odor of marijuana (e.g., stepping back, commenting on the smell, scratching their nose in discomfort).”

3.   “Fruit of the poisonous tree” is an exclusionary rule that encompasses not only primary evidence obtained as a direct result of an illegal search or seizure, but also evidence later discovered and found to be derivative of illegality. State v. Nicholas, 06-903, p. 6 (La. App. 5 Cir. 4/24/07) 958 So.2d 682, 686.

4.   Respondent asserts in his opposition to the State's writ application that the State waived its argument that probable cause existed to justify the warrantless search of Respondent's vehicle based on his possession of (and attempted destruction of) the suspicious pill and baggies in his pockets because it argued to the district court that probable cause was based on both Respondent's possession of narcotics and the smell of marijuana. Thus, Respondent argues that the State cannot now claim that the possession of the pill and baggies alone was sufficient to constitute probable cause. However, a review of the State's post-hearing memorandum to the district court makes clear that the State was advancing two separate theories of justification for the warrantless search of the vehicle and not that it relied on the cumulative circumstances as Respondent suggests.

5.   In Ross, the Supreme Court set forth the automobile exception as follows:(a) The “automobile exception” to the Fourth Amendment's warrant requirement established in Carroll v. United States, 267 U.S. 132, 45 S.Ct. 280, 69 L.Ed. 543, applies to searches of vehicles that are supported by probable cause to believe that the vehicle contains contraband. In this class of cases, a search is not unreasonable if based on objective facts that would justify the issuance of a warrant, even though a warrant has not actually been obtained. Pp. 2162–2164.(b) However, the rationale justifying the automobile exception does not apply so as to permit a warrantless search of any movable container that is believed to be carrying an illicit substance and that is found in a public place—even when the container is placed in a vehicle (not otherwise believed to be carrying contraband). United States v. Chadwick, 433 U.S. 1, 97 S.Ct. 2476, 53 L.Ed.2d 538; Arkansas v. Sanders, 442 U.S. 753, 99 S.Ct. 2586, 61 L.Ed.2d 235. Pp. 2165–2167.(c) Where police officers have probable cause to search an entire vehicle, they may conduct a warrantless search of every part of the vehicle and its contents, including all containers and packages, that may conceal the object of the search. The scope of the search is not defined by the nature of the container in which the contraband is secreted. Rather, it is defined by the object of the search and the places in which there is probable cause to believe that it may be found. For example, probable cause to believe that undocumented aliens are being transported in a van will not justify a warrantless search of a suitcase.Ross, 456 U.S. 798.

Judge Paula A. Brown

BELSOME, C. J., CONCURS IN THE RESULT