## Facts

- A Wilmington police detective monitored inbound trains for suspected drug couriers without any tip about specific individuals.
- Uriel C. Harris arrived by train, carried a backpack, looked over his shoulder several times, used a payphone, and met Dale Green.
- Harris entered a Ford Tempo with Maryland plates and sat in the back seat; the detective relayed observations to other officers.
- Delaware State Police stopped the vehicle based on the detective’s observations.
- After the stop, the occupants denied owning the backpack; police treated it as abandoned, searched it, and found more than 200 grams of cocaine.
- Harris was arrested, the trial court denied his motion to suppress, and he was convicted.

## Issues

1. Whether police had reasonable, articulable suspicion under the Fourth Amendment and Del. Const. art. I, § 6 to conduct an investigatory stop of the vehicle.
2. Whether the warrantless search of the backpack and seizure of cocaine were lawful, including whether “abandonment” validated the search after an unlawful stop.

## Decision

- The Delaware Supreme Court reversed.
- The court held police lacked reasonable, articulable suspicion to stop the vehicle.
- Because the stop was unconstitutional, the ensuing search and seizure were unlawful fruits of the stop, and the cocaine should have been suppressed.
- The occupants’ denial of ownership did not cure the prior illegality of the stop for purposes of admitting the evidence.

## Legal Principles

- Reasonable suspicion requires specific, articulable facts and rational inferences under the totality of the circumstances; an inchoate and unparticularized suspicion or hunch is insufficient.
- Lawful, seemingly innocent conduct may contribute to reasonable suspicion only when an officer explains concrete reasons linking the conduct to suspected criminal activity.
- Generalized assumptions about drug trafficking patterns, without individualized and articulable suspicion, do not justify a seizure.
- Evidence obtained as a result of an investigatory stop lacking reasonable suspicion must be suppressed under the Fourth Amendment and Del. Const. art. I, § 6.

## Conclusion

The court held that police reliance on commonplace travel behavior and generalized drug-courier assumptions did not establish reasonable suspicion to stop the vehicle; because the stop was unlawful, the cocaine discovered in the backpack was inadmissible, requiring reversal of Harris’s conviction.


Harris v. State, 806 A.2d 119 (Del. 2002)