State v. Estrada-VitalAnnotate this Case
Law enforcement officers stopped Defendant’s vehicle for displaying an improper license. An officer had Defendant, the driver, and his passenger exit the vehicle and searched the vehicle, which led to the seizure of a wallet from inside the vehicle. The wallet contained Defendant’s identification, which led to the discovery that Defendant’s driver’s license was revoked. The officers placed Defendant under arrest and conducted a pat-down search that produced cocaine from Defendant’s pants pocket. Defendant filed a motion to suppress the cocaine. The district court denied the motion. Defendant appealed, arguing that his arrest was illegal and the subsequent search incident to arrest was invalid as fruit of the poisonous tree. The court of appeals affirmed on procedural grounds, noting that the district court did not have an opportunity to consider and rule upon the search and seizure challenge that Defendant presented on appeal. The Supreme Court affirmed the court of appeals’ refusal to entertain the merits of Defendant’s arguments, holding that defense counsel’s stipulations in the district court prevented the evidentiary inquiry necessary to produce the factual findings below that would permit appellate consideration of Defendant’s fruit of the poisonous tree theory without speculation as to what the facts might have been.