Colorado v. Webb
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In an interlocutory appeal, the issue this case presented to the Colorado Supreme Court was whether the trial court erred when it suppressed evidence that the police found in defendant-appellee Lynette Webb's purse. In a visit with defendant's son, officers found spoons with methamphetamine residue under the son's bed, and a syringe that tested positive for methamphetamine in a visitor's backpack. Upon executing a search warrant of the house (and all personal property within) based on the visit with the son, officers found methamphetamine paraphernalia in defendant's purse. The trial court concluded that defendant had a heightened expectation of privacy to the purse, and that officers' search was unreasonable because it was unlikely that the son would hide contraband in his mother's purse. The Supreme Court concluded the trial court applied the wrong analysis: "[o]nce a lawful search warrant is issued, the scope of the search is defined by the scope of the warrant rather than an individual's expectation of privacy in any particular area or item." The Court therefore reversed the trial court's ruling and remanded the case for further proceedings.
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