United States v. Currence

446 F.3d 554 (4th Cir. 2006)

Facts

Police received information from a confidential informant that a man on a bicycle was selling drugs on a street corner in Richmond. The informant gave a detailed description of the man.

They approached D, who matched the description given by the informant. At the police request, D stepped off the bicycle and was frisked. The frisk uncovered money, but no drugs or weapons.

D identified himself to the detectives, and they ran a radio check on him. D had an outstanding criminal warrant. The detectives then handcuffed D and placed him under arrest pending confirmation of the warrant. Detectives then searched the bicycle that was next to D. They were aware that drug dealers sometimes use hollow areas on bicycles to attempt to conceal drugs. Without using any tools, they slid off the end cap from the right handlebar and discovered plastic baggies containing what appeared to be crack cocaine inside the handlebar. D was informed of his rights, and he made incriminating statements. A subsequent test of the substance found in the handlebar indicated that it was crack cocaine. D moved to suppress the crack cocaine.