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KY: Nervousness, questioning why officers asked about passengers, and refusal to consent doesn't justify frisk

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Defendant was stopped for littering and not using a turn signal. When he was stopped, he was nervous and his hands were shaking. One officer asked who was in the car with him, and he asked “Does it matter?” The other officer described defendant as “verbally belligerent” when ordered out of the car, but didn’t hear what was said. He refused consent. A patdown for weapons was unjustified, and the marijuana in defendant’s pocket was suppressed. Frazier v. Commonwealth, 2013 Ky. LEXIS 368 (August 29, 2013). Defendant had no standing in the place searched. While his DL showed that address, he conceded he lived elsewhere. Mackey v. Commonwealth, 2013 Ky. LEXIS 378 (August 29, 2013).*

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