STATE OF LOUISIANA v. COLE MEEKS (2025)

Writ application granted. See per curiam.

PDG

JLW

JDH

WJC

JBM

JMG

CRC

Supreme Court of Louisiana December 10, 2025

SUPREME COURT OF LOUISIANA

No. 2025-KK-01511

STATE OF LOUISIANA

VS.

COLE MEEKS

On Supervisory Writ to the Criminal District Court, Parish of Orleans Criminal

PER CURIAM

Writ granted. “In reviewing the totality of circumstances for whether reasonable suspicion existed for making an investigatory 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. A reviewing court should give deference to the inferences and deductions of a trained police officer that might well elude an untrained person.” State v. Greenberry, 14-1126, p. 1 (La. 4/10/15), 164 So.3d 824, 825 (internal citations omitted).

The district court abused its discretion relying on State v. Davis, wherein this Court specifically observed the officers testified they “could not ․ readily distinguish between tobacco and marijuana hand-rolled cigarettes.” 359 So.2d 986, 989 (La. 1978). The officer in this matter testified he observed the defendant in the act of rolling “green vegetable material” into a hand-rolled cigarette. Thus, the officer did not simply observe a hand-rolled cigarette, he observed the contents that were being rolled into the cigarette itself. The officer further testified that, based on his training, he suspected this to be marijuana. We find this sufficient to establish reasonable suspicion for the officer to conduct the initial investigatory stop. Accordingly, the ruling of the district court granting defendant's motion to suppress and finding of no probable cause is reversed and the matter is remanded for further proceedings.

REVERSED AND REMANDED