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  5. Breaking News, What You Need To Know: Court Of Appeals Finds Evidence Of Meth Found At Taco Bell Properly Admitted At Trial

Breaking News, What You Need To Know: Court Of Appeals Finds Evidence Of Meth Found At Taco Bell Properly Admitted At Trial

On Behalf of Dixon & Moseley, P.C. | Aug 8, 2019 | Appellate Practice, Drug Possession, Indiana Court of Appeals

The Fourth Amendment of the United States Constitution protects you from illegal searches and seizures. This means that when police officers illegally conduct searches and illegally seize items, evidence obtained as a result of the illegal search and/or seizure cannot be used against the individual to convict them. The starting point in determining whether the search or seizure was illegal depends on the circumstances. To claim that there was an illegal seizure of the person, one must be in police custody and be subject to police interrogation. To claim there was an illegal search, one must establish that they had a “reasonable expectation of privacy.” As one may imagine, these cases are fact-sensitive inquiries. Not every police encounter is an interrogation, nor is every search illegal. In a recent decision analyzed in this blog, the Court of Appeals reiterated this legal point in its decision of Canfield v. State1.

In Canfield, the Indiana Court of Appeals upheld the admission of evidence of meth found at a Taco Bell following a police search of the restaurant. The relevant facts are as follows: In May of 2018, Police Major Bridges was made aware of an anonymous tip that a male employee at Taco Bell may be selling illegal drugs. Furthermore, the anonymous tip stated that the employee may have the drugs on his person. Acting on this tip, Major Bridges, along with another officer, arrived at the Taco Bell within a few minutes. Upon arriving, Major Bridges identified the individual, Canfield, based on the description received from the tip. Major Bridges asked Canfield if they could speak outside. Canfield agreed but stated that he needed to ask his manager for permission. While going to ask the manager, the officers saw Canfield “dig around his waistband area” and drop something by the food preparation area. The two officers and Canfield then went outside, and the officers informed Canfield of the allegations. The officers observed Canfield become “very nervous.” Major Bridges then went inside the Taco Bell to search the area where they had observed Canfield digging in his waistband. Major Bridges then asked the manager for permission to search the area, and the manager consented. Major Bridges found over four grams of methamphetamine, and Canfield was arrested for possession.

At trial, Canfield filed a motion to suppress the evidence, arguing that the officers illegally detained him, and that the search was illegal. The trial court denied the motion and Canfield was ultimately convicted. Canfield appealed. On appeal, Canfield argued that the trial court erred in admitting the evidence because it violated his Fourth Amendment rights against illegal search and seizure. In upholding the conviction, the Court of Appeals first noted that the search of the Taco Bell was not illegal because Canfield had no reasonable expectation of privacy at this location. Furthermore, the Court noted that a “well-recognized exception to the warrant requirement is a voluntary and knowing consent to search.” Because the manager consented to the search, the Court found that there was no Fourth Amendment violation. In finding that the evidence was not illegally seized, the Court stated that “not all encounters between law enforcement and citizens implicate the protections of the Fourth Amendment.” The Court went on to state that “consensual encounters” where a person voluntarily talks to the police does not implicate the Fourth Amendment. Here, the Court found that Canfield willingly went outside to talk to the officers, and that Canfield was free to leave the encounter. As such, the Court found that Canfield’s Fourth Amendment rights were not violated.

This area of law is extremely technical, while also having the potential to completely change the course of your life and result in arrest and conviction. An individual who is unaware of their rights may have them violated without even knowing leading to a negative result such as arrest and conviction in this case. The importance of understanding the status of developments in the law is the key to avoiding criminal liability, as well as being an engaged citizen in our participatory system of government. This blog post on a key new case was written by attorneys at Dixon & Moseley, P.C. who handle criminal defense cases and appeals of criminal convictions throughout the state. Knowing the law is a key to be an engaged citizen. Having criminal defense counsel current on the latest developments in law provides you with the best criminal defense. This blog is written for educational purposes only. It is not intended as legal advice or a solicitation for services. It is an advertisement.

  • Kristapher D. Canfield v. State of Indiana, 18A-CR-3124 (Ind. Ct. App. 2019).
  • How Many Days Do You Have to Appeal in Indiana? (2026)

    On Behalf of Dixon & Moseley, P.C. | Jul 15, 2026 | Firm News

    An Indiana appellate lawyer’s guide to Notice of Appeal deadlines, Motions to Correct Error, interlocutory appeals, and common timing mistakes. Quick Answer: How Many Days Do You Have to Appeal a Case in Indiana? In most Indiana appeals from a final judgment, the...

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    On Behalf of Dixon & Moseley, P.C. | Jul 9, 2026 | Uncategorized

    A practical Indiana appellate lawyer’s guide to Notice of Appeal deadlines, appealable orders, the appellate record, briefing, oral argument, rehearing, and transfer to the Indiana Supreme Court. If you lost a civil case in Indiana, you may wonder whether the trial...

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    On Behalf of Dixon & Moseley, P.C. | Jul 1, 2026 | Uncategorized

    When a civil case does not go your way in an Indiana trial court, an appeal may provide a path to reversal, but only if certain legal errors occurred. Indiana appellate courts do not retry cases or reweigh evidence. Instead, they review whether the trial court...

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    On Behalf of Dixon & Moseley, P.C. | Jun 25, 2026 | Uncategorized

    Adoption in Indiana typically requires the consent of a child’s biological parents. However, Indiana law provides several important exceptions where a court may allow an adoption to proceed without a parent’s consent. Understanding these exceptions is critical;...

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    On Behalf of Dixon & Moseley, P.C. | Jun 9, 2026 | Uncategorized

    An Indiana Litigation Guide for Preserving Error on Appeal In Indiana litigation, one of the most common mistakes a trial lawyer can make is failing to object at the right time and in the right manner. The rule is simple but unforgiving: if you do not properly object, you may waive the issue for appeal. An objection must be timely…

    Waiver on Appeal: The #1 Reason Appeals Lose in Indiana

    On Behalf of Dixon & Moseley, P.C. | Jun 2, 2026 | Uncategorized

    In Indiana appellate practice, many appeals do not fail because the underlying issue lacked merit. They fail because the issue was waived. In plain terms, waiver means the appellate court will not decide an argument because it was not properly preserved in the trial court, properly supported on appeal, or properly presented under the Indiana Rules of Appellate Procedure. Common…

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    On Behalf of Dixon & Moseley, P.C. | May 28, 2026 | Uncategorized

    Executive Summary There are several things that an attorney can do to ensure that an error is preserved for appeal. Making timely and specific objections and obtaining an explicit ruling from the judge on such objections can ensure that a matter is preserved. If evidence is excluded, the attorney should make offers of proof through questioning the witness outside of…

    Can a mother legally deny parenting time to an unmarried father?

    On Behalf of Dixon & Moseley, P.C. | May 10, 2026 | Uncategorized

    The answer depends on several important legal factors, including paternity, custody orders, and the best interests of the child. An unmarried mother has sole legal custody in Indiana unless a court orders otherwise. An unmarried father does not have enforceable rights until paternity is established by either signing a paternity affidavit or filing a paternity action in court. If paternity…

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    On Behalf of Dixon & Moseley, P.C. | Apr 23, 2026 | Uncategorized

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    On Behalf of Dixon & Moseley, P.C. | Apr 21, 2026 | Uncategorized

    Retirement accounts are generally considered marital property to the extent that were earned during marriage. Although retirement funds that accumulated before the marriage are not automatically excluded from the marital property, they can affect how the marital property is divided. 401(k)s and employer-sponsored retirement plans are divided using a Qualified Domestic Relations Order (QDRO), which is a court order directing…

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    • How Many Days Do You Have to Appeal in Indiana? (2026)
    • How to Appeal a Case in Indiana: Step-by-Step Guide, Deadlines, Costs, and Common Mistakes (2026)
    • Common Grounds for Appeal in Indiana Civil Cases (Complete Guide)
    • When Is Parental Consent NOT Required for Adoption in Indiana? (2026 Guide)
    • Failure to Object: When Is an Issue Waived?

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