Oregon v. Maciel-Figueroa
Annotate this CaseAt issue in this case was whether police officers violated the prohibition against unreasonable seizures in Article I, section 9, of the Oregon Constitution, when they responded to a report that a named man was threatening to break things in a house, they saw defendant walking away from the house, and they ordered him to stop and return for questioning. The trial court concluded that the officers had reasonable suspicion to stop defendant to investigate whether he had committed a crime; thus, it denied defendant’s motion to suppress evidence resulting from the stop. The Court of Appeals reversed. The Supreme Court granted the State's petition for review to consider whether the Court of Appeals "erroneously heightened the standard" that the State must establish that an investigatory stop was supported by reasonable suspicion. The State contended that the Court of Appeals required the state to show that, before stopping defendant, the police had confirmed that he had committed a crime. Although there has been some variation in the Supreme Court’s articulation of the standard, the established standard for reasonable suspicion supporting an investigatory stop of a defendant is met when an officer can point to specific and articulable facts that give rise to a reasonable inference that the defendant committed or was about to commit a specific crime or type of crime. The Court of Appeals correctly applied the reasonable-suspicion standard to the facts established at the suppression hearing, which concerned whether it was reasonable for the officers to infer that defendant had committed a crime. Accordingly, the Court affirmed the decision of the Court of Appeals and reversed the judgment of the trial court.
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