State v. Andrade-ReyesAnnotate this Case
The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress evidence on the ground that incriminating evidence was obtained as the result of an unlawful seizure, holding that officers unlawfully detained Defendant and conducted an illegal search.
Defendant was seated in a car lawfully parked in an apartment complex parking lot when two officers approached the car. Defendant's hands were clenched and held in front of him, and one officer commanded Defendant to open his hand. Defendant opened his hand and dropped a small bag of cocaine. Defendant moved to suppress the evidence, but the district court denied the motion, finding that the encounter was voluntary. The court of appeals affirmed. The Supreme Court reversed and remanded for further proceedings, holding that the detention was unlawful because the officer lacked reasonable suspicion of criminal activity to detain Defendant, and therefore, the evidence obtained as a result must be suppressed because it was tainted by an unlawful seizure.