Colorado v. Guthrie
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In this interlocutory appeal, the prosecution challenged a district court order that granted defendant Suzanne Guthrie's motion to suppress evidence of an illegal narcotic discovered during a routine inventory search of her personal effects after a judge at the El Paso County Court, in a prior proceeding, ordered a deputy sheriff to jail her for direct contempt of court. In the prosecution for Defendant's possession of illegal drugs, the district court suppressed evidence discovered during the inventory search as an ad hoc remedy for the due process violation it deemed the county court judge committed when conducting the contempt proceeding. Upon review, the Supreme Court held that there was no violation of the Fourth Amendment: the inventory search resulted directly from the county court's order to the deputy sheriff, based on a finding of criminal contempt of court to jail Defendant. Appeal of the summary contempt conviction, which might or might not result in reversal, would be the proper recourse for the county court's alleged due process violation. Suppressing evidence of the illegal narcotic discovered as a result of the valid inventory search here would not have been an appropriate remedy even if the county court erred in convicting Defendant of direct contempt of court.
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