State v. TeamerAnnotate this Case
Defendant was charged with drug trafficking and possession after the vehicle he was driving was stopped by a deputy sheriff who had noticed an inconsistency between the actual color of the vehicle and the color indicated on the vehicle’s registration. Defendant moved to suppress the results of the stop as products of an unlawful, warrantless search. The trial court denied the motion to suppress, concluding that the vehicle was legally stopped for investigative purposes and that the odor of marijuana emanating from inside the vehicle gave the officer probable cause to conduct a search. Defendant was subsequently convicted. The district court reversed the denial of Defendant’s motion to suppress, concluding that a color discrepancy alone does not provide reasonable suspicion for an investigatory stop. The Supreme Court affirmed, holding that a color discrepancy, standing alone, does not justify initiating a stop to determine if the law has been violated.