Adams v. State (2004)
In Adams v. State, 103 P.3d 908 (Alaska App. 2004) a police officer contacted two men (Adams and Linn) at night. The Court summarized the situation as follows: "Adams and Linn were parked on a dead-end street at night; the dead-end street was near a grade school that had been frequently vandalized; when questioned, Adams and Linn gave apparently conflicting accounts of why they were stopped in the area."
The officer stated that Adams appeared to be very nervous when he questioned him. The officer also stated that Adams was constantly taking his hands in and out of his pockets. But the officer conceded that it was cold outside and that he had never asked Adams to keep his hands out of his pockets.
The Court concluded that the officer had not given "a convincing reason why he thought Adams might be armed and dangerous" and held that the officer had no basis to conduct a pat-down search.