State v. Jones
Annotate this CaseDefendant was arrested for possession of cocaine and possession of drug paraphernalia. Defendant filed a motion to suppress the evidence obtained during a warrantless search of her vehicle conducted incident to a traffic stop. The district court granted the motion, concluding that the pretextual nature of the stop rendered the seizure constitutionally invalid. A divided court of appeals panel affirmed on other grounds, holding that the law enforcement officer did not have a reasonable suspicion that justified the search. The dissenting member of the panel argued that the case should be reversed and remanded for additional findings as to whether a reasonable suspicion existed, as an appellate court cannot engage in factfinding. The Supreme Court affirmed, holding that the evidence was properly suppressed, as (1) an appellate court conducts a de novo review of the totality of the circumstances to determine whether reasonable suspicion exists; (2) the undisputed facts and the district judge’s findings of fact were sufficient for appellate review of the totality of the circumstances; and (3) based on that review, the court of appeals correctly found that the search in this case was invalid because the circumstances did not establish a reasonable suspicion that justified a search of the vehicle.
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