State v. Colin – Case Brief Summary (Washington)

State v. Colin, 61 Wn. App. 111, 809 P.2d 228, disc. review denied, 117 Wn.2d 1009, 816 P.2d 1223 (1991), involved a warrant issued based on information from a confidential informant. Colin, 61 Wn. App. at 112. When the warrant was executed, Colin was subjected to a strip search and heroin was found in his underwear. Id. at 112.

Colin contended that the strip search was not authorized by the search warrant which authorized officers to "search the above described . . . person(s)." Id. at 114.

Acknowledging that a statement in the warrant application explaining "why a strip search was necessary and reasonable under the circumstances" would be useful to the court "in assessing the reasonableness of the search," the court concluded that there were "sufficient facts" in the record "to establish reasonableness." Id. at 115.

The search warrant was "for the express purpose of producing controlled substances likely to be found on . . . the person described in the warrant," and, the court stated, drugs "could be readily concealed on the person so that they would not be found without a strip search." Id.

Thus, the court held that the search was reasonable. Id. at 116.