State v. Mazuca (Original)
Annotate this CaseIn this felony prosecution for possession of ecstasy, the State appealed from the trial court's grant of defendant's motion to suppress evidence that defendant contended was obtained as a result of an illegal traffic stop. The court of appeals affirmed the trial court's ruling, holding that defendant's initial detention was illegal and that the taint emanating from the initial illegality was not attenuated by the fact that, immediately after the initial stop, defendant was found to have an outstanding arrest warrant that might have given rise to a valid search incident to arrest. The court of appeals adopted an approach that would effectively presume purposeful and/or flagrant police misconduct from the fact of the primary illegality alone rather than assessing the character of that illegality, and of any subsequent police conduct, to determine whether it indicated they they actually behaved purposefully or flagrantly in the particular case. Thus, the court held that the court of appeals erred to rely upon this de facto presumption to affirm the trial court's ruling on defendant's motion to suppress. Accordingly, the court reversed the judgment of the court of appeals.
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