State v. Rolon
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The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.
Defendant sought to suppress evidence seized after his warrantless detention in the parking lot of a multiunit apartment building. The trial court denied the suppression motion. The Supreme Court reversed, holding that Defendant was not an "occupant" within the "immediate vicinity" of the premises subject to a search warrant under the exception to the Fourth Amendment's warrant requirement set forth in Michigan v. Summers, 452 U.S. 692 (1981), and Bailey v. United States, 568 U.S. 186 (2013).
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