Tuesday, November 25, 2025
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Pat-Down Search Not Rendered Unnecessary Because Detainee Was Handcuffed, C.A. Says
By a MetNews Staff Writer
It was not unreasonable for a police officer to conduct a pat-down search of a detained suspect who was in handcuffs, Div. Six of this district’s Court of Appeal declared yesterday, rejecting the contention that the appellant could not have posed a danger to officers while restrained.
The search resulted in finding a handgun. Anthony Davis Williams subsequently pled no contest to being a felon in possession of a firearm but appealed from the denial by Los Angeles Superior Court Judge Mildred Escobedo of his suppression motion.
“A reasonably prudent person would not believe that a handcuffed individual poses a threat to his or her safety,” Williams argued, maintaining that he could not “easily escape” or reach a weapon. Acting Presiding Justice Kenneth Yegan, in an unpublished opinion affirming the judgment of conviction, responded:
“Although handcuffs may temporarily restrain a person, there is still a risk that a suspect will flee or do an officer harm.”
He quoted the U.S. Supreme Court’s 1968 opinion in Terry v. Ohio, authored by Chief Justice Earl Warren, as saying that it would be “unreasonable to deny an officer the power to take necessary measures to determine whether the person is in fact carrying a weapon and to neutralize the threat of physical harm.”
Yegan also quoted one of his own opinions, as he has a tendency to do, setting forth:
“The judiciary should not lightly second-guess a police officer’s decision to perform a patdown search for officer safety. The lives and safety of police officers weigh heavily in the balance of competing Fourth Amendment considerations.”
That utterance came in 1994 in People v. Dickey.
High-Prostitution Area
The pat-down search was conducted by Los Angeles Police Officer Julia Varela. She observed Williams, along with other men, acting aggressively toward a group of women in provocative clothing along the Figueroa Corridor—a three-mile strip in the USC area labeled by the New York Times on Oct. 26 “one of the most notorious sex-trafficking corridors in the United States.”
Williams was committing a traffic violation and she suspected him of pandering. Yegan wrote:
“Appellant was parked in the middle of the street, blocking traffic, and standing outside of his vehicle, a violation of Vehicle Code section 22500. It was after midnight. The area was ‘notoriously known’ for human trafficking, prostitution, pimping and pandering. Appellant was shouting and behaving ‘aggressively’ toward the women, who were believed to be commercial sex workers. When Officer Varela activated her patrol lights, appellant attempted to get back into his vehicle, he appeared ‘very nervous,’ ‘fidgety,’ and was ‘uncooperative.’
“These factors, taken together, are sufficient to support a reasonable suspicion that appellant was armed and dangerous. Indeed, Officer Varela testified that in her experience, individuals who exhibit these indicators usually have a weapon on them, as was the case here.”
The case is People v. Williams, B340087.
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