Opinion handed down January 12, 2016
In 2012, Derrick Carrawell was arrested for peace disturbance. While Carrawell was already handcuffed and seated in the back of a police car, a police officer searched a plastic grocery bag Carrawell dropped in the process of the arrest. The officer discovered heroin. Carrawell asserted the search of his bag was not lawful under the Fourth Amendment and moved to suppress the evidence of the heroin, but the trial court denied this motion. Carrawell appealed his conviction of possession of a controlled substance, arguing that the trial court abused its discretion in denying a motion to suppress evidence of heroin. The Supreme Court of Missouri abrogated previous cases and narrowed the scope of lawful police searches in Missouri in agreeing with Carrawell that the search was not lawful. It nevertheless affirmed the trial court’s judgment, however, holding that the exclusionary rule did not apply.