State v. Vasquez
In State v. Vasquez, 167 Ariz. 352, 807 P.2d 520 (1991), the Arizona Supreme Court found permissible an officer's search of the pockets of a suspect's jacket.
In Vasquez, a domestic violence suspect who had been drinking and was emotionally upset asked for his jacket before entering a police vehicle. See id. at 353, 807 P.2d at 521.
The officer responded that he would have to search the bulky jacket before he could give it to the suspect. See id.
The suspect did not object. See id.
In one of the pockets, the officer found cocaine. See id.
In finding the search reasonable, the court focused upon the volatile nature of domestic dispute encounters and the crucial question "whether a reasonably prudent officer in the circumstances would be warranted in the belief that his safety or that of others was in danger." Id. at 355, 807 P.2d at 523.
The court noted that, because of the bulkiness of the jacket, "the officer could not tell from the pat-down alone what, if anything, the jacket pockets contained":
"A dangerous weapon may well have been inside." Id. at 356, 807 P.2d at 524.