In lower court, Dickerson moved that the cocaine be suppressed as evidence because the officer violated his right against unreasonable search and seizure under the Fourth Amendment to the United States Constitution, but the trial court overruled this objection, ruling that the frisking and the seizure of the cocaine were justified.

[2] The state Supreme Court held that both the stop and the frisk of respondent were valid under Terry v. Ohio,[3] but found the seizure of the cocaine to be unconstitutional.

[4] Refusing to enlarge the "plain-view" exception to the Fourth Amendment's warrant requirement, the court appeared to adopt a categorical rule barring the seizure of any contraband detected by an officer through the sense of touch during a patdown search.

The court further noted that, even if it recognized such a "plain-feel" exception, the search in this case would not qualify because it went far beyond what is permissible under Terry.

[1] If a police officer lawfully pats down a suspect's outer clothing and feels an object whose contour or mass makes its identity immediately apparent, there has been no invasion of the suspect's privacy beyond that already authorized by the officer's search for weapons; if the object is contraband, its warrantless seizure would be justified by the same practical considerations that inhere in the plain-view context.