State v. Portillo

I attest to the accuracy and
integrity of this document
New Mexico Compilation
Commission, Santa Fe, NM
'00'04- 13:41:58 2011.08.22

Certiorari Denied, June 28, 2011, Docket No. 33,044

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

Opinion Number: 2011-NMCA-079

Filing Date: April 1, 2011

Docket No. 29,564

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

ARTURO PORTILLO,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY
Douglas R. Driggers, District Judge

Gary K. King, Attorney General
Margaret E. McLean, Assistant Attorney General
Joel Jacobsen, Assistant Attorney General
Santa Fe, NM

for Appellee

Law Works L.L.C.
John A. McCall
Albuquerque, NM

for Appellant

OPINION

FRY, Judge.

{1} Defendant challenges the denial of his motion to suppress. We conclude that
Defendant, a passenger in a vehicle subjected to a valid traffic stop, was illegally detained
when the stop was extended by the officer’s questions, which were unrelated to the reason
for the stop and unsupported by independent reasonable suspicion. Because the evidence

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sought to be suppressed was the fruit of that illegal detention, we reverse the district court’s
order denying suppression.

STANDARD OF REVIEW

{2} “In reviewing a trial court’s denial of a motion to suppress, we observe the
distinction between factual determinations which are subject to a substantial evidence
standard of review and application of law to the facts[,] which is subject to de novo review.”
State v. Nieto, 2000-NMSC-031, ¶ 19, 129 N.M. 688, 12 P.3d 442 (alteration in original)
(internal quotation marks and citation omitted). “We view the facts in the manner most
favorable to the prevailing party and defer to the district court’s findings of fact if substantial
evidence exists to support those findings.” State v. Urioste, 2002-NMSC-023, ¶ 6, 132 N.M.
592, 52 P.3d 964.

{3} For the factual background in this case, we rely primarily on the district court’s
formal findings of fact that are undisputed by the parties. We supplement these findings with
additional information upon which the record is unequivocal and the parties are in
agreement.

BACKGROUND

{4} Officer Dean Thatcher was the only witness at the hearing on the motion to suppress.
He testified that he initiated a routine traffic stop for a speeding violation on July 19, 2008.
Defendant was a passenger in the vehicle. Officer Thatcher asked the driver for his license,
proof of insurance, and registration. As the driver searched for these documents, Defendant
remained looking straight ahead with his hands in his lap, avoiding eye contact with Officer
Thatcher and only glancing furtively at him once when Officer Thatcher moved. Officer
Thatcher found this behavior to be abnormal, and it caused him to suspect that there were
narcotics or weapons in the vehicle. Therefore, when Officer Roy Askin arrived on the
scene, Officer Thatcher asked him to watch Defendant.

{5} Officer Thatcher asked the driver to step out of the vehicle and issued a citation to
him. Officer Thatcher then returned the documents to the driver and told him that he was
free to leave. However, as the driver was walking back toward his vehicle, Officer Thatcher
asked whether he had any illegal narcotics or weapons in the vehicle. The driver indicated
that there were none. Officer Thatcher requested and obtained the driver’s consent to search
the vehicle.

{6} Officer Thatcher then approached Defendant and asked him whether there were any
weapons or narcotics in the vehicle and whether the vehicle contained any of Defendant’s
personal property. Defendant responded in the negative and, upon the officer’s request,
Defendant also consented to a search of the vehicle. After Defendant exited the vehicle,
Officer Thatcher asked Officer Askin to continue to watch Defendant.

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{7} In the course of the ensuing search of the vehicle, Officer Thatcher discovered illegal
narcotics. Defendant admitted ownership. He was arrested and later charged with
possession of a controlled substance.

{8} Defendant moved to suppress on the ground that he had been impermissibly detained
in the course of the traffic stop and further argued that the scope of the investigatory
detention had been improperly expanded to include drug-related questioning without
reasonable suspicion. Based on these alleged illegalities, Defendant contended that the
evidence obtained in the course of the search of the vehicle, as well as all other evidentiary
fruits of the search, should be suppressed. The district court denied the motion. Defendant
entered a plea agreement, in which he reserved the right to challenge the district court’s
ruling on the motion. This appeal followed.

DISCUSSION

Standing

{9} Because this case involves the search of a vehicle in which Defendant was a
passenger, standing is presented as a threshold question. See generally State v. Van Dang,
2005-NMSC-033, ¶ 7, 138 N.M. 408, 120 P.3d 830 (characterizing standing as a threshold
issue). The district court concluded that Defendant had “standing to file his [m]otion to
[s]uppress,” but did not elaborate. An overview of the applicable principles of law is
helpful.

{10} Generally speaking, passengers lack a reasonable expectation of privacy in vehicles
or their contents and, as a consequence, passengers typically lack standing to challenge
automobile searches. See, e.g., State v. Waggoner, 97 N.M. 73, 75, 636 P.2d 892, 894 (Ct.
App. 1981) (holding that passengers lacked any reasonable expectation of privacy and
therefore had no standing to challenge the search of the vehicle). A showing of special
circumstances, such as status as a regular permissive user who exerts control over the vehicle
and its contents, may support a different result in an appropriate case. See Van Dang, 2005-
NMSC-033, ¶¶ 8-10 (discussing circumstances in which a non-owner may have standing to
challenge a vehicle search). In this case, however, no such showing was made. We
therefore conclude that Defendant lacked standing to directly challenge the search of the
vehicle.

{11} Although an individual may lack standing to directly challenge a search of a vehicle,
he or she may nevertheless contest the lawfulness of his or her own detention and seek to
suppress evidence found as a result of that detention. See id. ¶¶ 12-13 (observing in a case
where the defendant lacked standing to challenge the search of a vehicle that he nevertheless
had standing to challenge the constitutionality of his own detention); State v. Creech, 111
N.M. 490, 492, 806 P.2d 1080, 1082 (Ct. App. 1991) (observing that while a passenger may
lack a privacy interest sufficient to establish standing to challenge a vehicle search, a
passenger nevertheless has standing to challenge the validity of the stop). Accordingly, to

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the extent that Defendant was illegally detained, Defendant has standing to seek the
suppression of any evidence obtained as a result of that detention. See State v. Sewell, 2009-
NMSC-033, ¶ 16, 146 N.M. 428, 211 P.3d 885 (observing that a defendant has standing to
object to a seizure “which occurred as a result of the exploitation of [the d]efendant’s own
unlawful . . . detention” (omission in original) (internal quotation marks and citation
omitted)). In light of the foregoing principles, we must first ascertain whether Defendant
was illegally detained.

Illegal Detention

{12} It is well established that the initiation of a traffic stop constitutes a seizure of the
vehicle’s occupants. State v. Leyva, 2011-NMSC-009, ¶ 10, ___ N.M. ___, 250 P.3d 861
(explaining that “[a] law enforcement officer who stops a vehicle to investigate a traffic
violation seizes the occupants”). Accordingly, Defendant was clearly seized when Officer
Thatcher stopped the vehicle in which he was traveling as a passenger, and he would have
standing to challenge that stop. See Creech, 111 N.M. at 492, 806 P.2d at 1082. However,
Defendant does not take issue with the validity of the stop itself.

{13} Defendant contends that the stop ripened into an unlawful investigatory detention
when Officer Thatcher improperly expanded the scope of inquiry beyond the circumstances
that justified the initial stop. More specifically, he asserts that once Officer Thatcher
completed his investigation relative to the speeding violation and issued the citation, the stop
should have concluded. Defendant argues that the officer’s inquiry about the presence of
narcotics and weapons in the vehicle without reasonable suspicion for doing so
impermissibly continued the detention. See generally State v. Funderburg, 2008-NMSC-
026, ¶ 14, 144 N.M. 37, 183 P.3d 922 (“An officer’s continued detention of an individual,
while lawful at the outset, may become unlawful if the officer unjustifiably expands the
scope of the detention or, without a valid factual basis, makes inquiries about other criminal
activity unrelated to the traffic violation.”).

{14} Defendant contends that the impermissible questioning directly implicated his own
constitutional rights because he was detained himself while the officer engaged in the
narcotics- and weapons-related inquiry. The State takes a different position. While
acknowledging that Defendant was effectively seized when the traffic stop was initiated, the
State contends that his detention was concluded when the vehicle came to a stop, at which
point Defendant was free to leave.

{15} We appear to lack authority addressing the specific situation presented in this case.
Although a series of cases have established that a passenger is detained if an officer requests
his or her identification, no such request was made of Defendant in this case. See, e.g., City
of Roswell v. Hudson, 2007-NMCA-034, ¶¶ 13-14, 141 N.M. 261, 154 P.3d 76; State v.
Patterson, 2006-NMCA-037, ¶ 21, 139 N.M. 322, 131 P.3d 1286; State v. Affsprung,
2004-NMCA-038, ¶ 18, 135 N.M. 306, 87 P.3d 1088. We must therefore apply more
general principles.

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{16} “A seizure takes place when the officer detains the individual in such a way that a
reasonable person would not feel free to leave, given the totality of the circumstances.”
Patterson, 2006-NMCA-037, ¶ 18. “[I]n determining whether a passenger in a detained
vehicle would feel free to leave . . . three factors are to be considered: (1) the conduct of the
police, (2) the person of the individual citizen, and (3) the physical surroundings of the
encounter.” Id. ¶ 20 (internal quotation marks and citation omitted).

{17} In this case, the encounter began with a display of authority sufficient to effectuate
the traffic stop. Soon afterward, a second officer arrived on the scene as well. This officer
was specifically requested to watch Defendant. Although the district court’s findings do not
specifically address the matter, the uncontroverted testimony of Officer Thatcher indicates
that Defendant was also individually questioned about the presence of narcotics and weapons
in the vehicle. Cf. State v. Figueroa, 2010-NMCA-048, ¶¶ 2, 20, 148 N.M. 811, 242 P.3d
378 (relying on uncontroverted testimony of the officer to establish circumstances
surrounding an encounter where the officer was the sole witness at a suppression hearing),
cert. granted, 2010-NMCERT-006, 148 N.M. 584, 241 P.3d 182. Finally, there was no
evidence suggesting that Defendant was ever informed that he was free to terminate the
encounter or to refuse to answer questions. We conclude that under such circumstances, a
reasonable person would not feel free to leave. The fact that Defendant was initially seized
with a show of authority and kept under constant scrutiny by two officers throughout the
remainder of the traffic stop, together with the fact that Defendant was subjected to
questioning about narcotics and weapons himself, is consistent with a continuous detention.
See, e.g., State v. Jason L., 2000-NMSC-018, ¶¶ 17-18, 129 N.M. 119, 2 P.3d 856 (observing
that circumstances such as a threatening presence of several officers, accusatory or intrusive
questioning of individuals, and failure to inform the individuals that they were free to leave
or not required to answer questions, are all factors that could lead a reasonable person to
believe he or she is not free to terminate an encounter with the police).

{18} Because Defendant remained subject to continuous detention, the question becomes
whether his detention was supported by reasonable suspicion. See generally Funderburg,
2008-NMSC-026, ¶ 24 (observing that questions about drugs and weapons are a distinct line
of inquiry and “must be supported by a showing of reasonable suspicion of criminal activity
other than that which gave rise to the initial traffic stop” (internal quotation marks and
citation omitted)); State v. Prince, 2004-NMCA-127, ¶ 9, 136 N.M. 521, 101 P.3d 332
(observing that “continued investigation beyond the scope of the initial traffic stop is
justified only if the officer can articulate specific and particularized factors that give rise to
an objectively reasonable suspicion that other criminal activity has been or may be afoot”).
It is at this point that analysis under the Fourth Amendment to the United States Constitution
diverges from an analysis under Article II, Section 10 of the New Mexico Constitution.

{19} Our Supreme Court recently filed its opinion in Leyva, in which the Court clarified
that an officer’s actions following a valid traffic stop will be scrutinized differently under
the Federal Constitution than under the State Constitution. Leyva, 2011-NMSC-009, ¶¶ 21,
55. Under the Fourth Amendment, if an officer has made a valid traffic stop, “[a]n officer’s

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subsequent actions are not reasonably related in scope to the circumstances that caused him
to stop the vehicle if he detains its occupants beyond the time needed to investigate the
circumstances that caused the stop, unless he develops reasonable suspicion of additional
criminal activity in the meantime.” Leyva, 2011-NMSC-009, ¶ 19 (alteration in original)
(internal quotation marks and citation omitted). Thus, “[w]hether an officer’s questioning
measurably extends the length of a traffic stop remains the proper analysis under the Fourth
Amendment.” Id. ¶ 21.

{20} However, the analysis is different under Article II, Section 10 of the New Mexico
Constitution. According to the Leyva Court, that provision requires “a reasonable
justification for the initial stop and that all questions asked during the stop be reasonably
related to the reason for the stop or otherwise supported by reasonable suspicion.” 2011-
NMSC-009, ¶ 55. “Unrelated questions are permissible when supported by independent
reasonable suspicion, for reasons of officer safety, or if the interaction has developed into
a consensual encounter.” Id.

{21} It appears that Officer Thatcher’s questioning about narcotics and weapons would
pass muster under Fourth Amendment analysis. Those few questions, while unrelated to the
reason for the initial stop, did not appreciably extend the length of the traffic stop as a whole.
See Leyva, 2011-NMSC-009, ¶ 18 (observing that under Fourth Amendment analysis, “[t]he
questions posed during a traffic stop no longer need to be reasonably related to the initial
justification of the stop” as long as the length of the stop is not extended beyond “the time
required to conduct a reasonable investigation into the initial justification for the stop”).

{22} While there appears to be no Fourth Amendment violation under these circumstances,
it is clear that Defendant preserved his claim that the extension of the initial traffic stop
violated Article II, Section 10 of the State Constitution. The Court in Leyva clarified what
is required to preserve a claim under the State Constitution and stated that “[w]here a state
constitutional provision has previously been interpreted more expansively than its federal
counterpart, trial counsel must develop the necessary factual base and raise the applicable
constitutional provision in trial court.” Leyva, 2011-NMSC-009, ¶ 49. “[A] plethora of
precedent already interprets Article II, Section 10 more expansively than the Fourth
Amendment,” so Defendant was required only to raise that state provision below and
develop a factual record in support of his argument. Leyva, 2011-NMSC-009, ¶ 50
(internal quotation marks and citation omitted). Defendant did both, and we therefore turn
to an analysis of Defendant’s state constitutional argument.

{23} Under our State Constitution, Officer Thatcher could ask questions about narcotics
and weapons only if he had developed independent, reasonable suspicion giving rise to such
questions. See Funderburg, 2008-NMSC-026, ¶ 24. The only basis for suspicion of
criminal activity that the State articulated in the district court involved Defendant’s
demeanor when Officer Thatcher approached the vehicle and requested the driver’s
documentation. Officer Thatcher testified that Defendant’s posture, with his hands in his lap
while looking straight ahead and failing to make eye contact apart from a single furtive

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glance, was abnormal and caused him to suspect that there were narcotics or weapons in the
vehicle. We conclude that this behavior, standing alone and in the absence of any other
suspicious circumstances, was insufficient to give rise to a reasonable suspicion of criminal
activity. See, e.g., State v. Vandenberg, 2003-NMSC-030, ¶ 44, 134 N.M. 566, 81 P.3d 19
(observing that a nervous demeanor and failure to make eye contact did not give rise to
reasonable suspicion about the possession of drugs or other criminal activity sufficient to
support further detention of the occupants of a vehicle); State v. Gutierrez, 2008-NMCA-
015, ¶ 21, 143 N.M. 522, 177 P.3d 1096 (holding that a nervous and possibly furtive
demeanor was insufficient to give rise to reasonable suspicion to detain); Patterson,
2006-NMCA-037, ¶¶ 9, 29 (holding that nervous behavior and failure to make eye contact
did not give rise to reasonable, individualized suspicion).

{24} To summarize, Defendant was detained at the inception of the traffic stop, and he
remained subject to continuing detention thereafter. Although the stop was originally
justified, the ensuing expansion of the inquiry into weapons and narcotics was unsupported
by reasonable suspicion. We therefore conclude that Defendant was subjected to an illegal
detention.

Exploitation of the Illegality

{25} It is established law that evidence discovered as a result of the exploitation of an
illegal seizure must be suppressed unless it has been purged of its primary taint. See State
v. Garcia, 2009-NMSC-046, ¶¶ 14, 23, 147 N.M. 134, 217 P.3d 1032 (reciting the fruit of
the poisonous tree doctrine set forth in Wong Sun v. United States, 371 U.S. 471 (1963)).
We therefore turn to the question of whether the evidence discovered in the vehicle in this
case was found as a result of the exploitation of Defendant’s illegal detention.

{26} As stated earlier, we are unaware of any New Mexico authority addressing the
precise circumstances in this case. However, in this Court’s opinion in State v. Van Dang,
2004-NMCA-067, ¶ 16, 135 N.M. 719, 93 P.3d 1, rev’d on other grounds by Van Dang,
2005-NMSC-033, we cited the case of United States v. DeLuca, 269 F.3d 1128 (10th Cir.
2001), a case in which the circumstances were strikingly similar.

{27} In DeLuca, a New Mexico police officer stopped a vehicle in which the defendant
was a passenger. Id. at 1130. Upon the officer’s request, the driver and owner of the vehicle
produced valid documentation. Id. Observing that the occupants of the vehicle appeared to
be nervous, the officer inquired about their travel plans. Id. Meanwhile, a second officer
arrived on the scene. Id. Permission to search the trunk of the vehicle was requested, and
the driver consented. Id. Narcotics were subsequently found, and all of the occupants of the
vehicle were arrested for possession. Id. at 1131. The defendant subsequently moved to
suppress the narcotics found in the course of the search. Id.

{28} On appeal, the DeLuca majority opinion noted that as a passenger, the defendant
lacked standing to directly challenge the search of the vehicle. Id. at 1132. Nevertheless,

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the defendant had standing to contest the lawfulness of his own detention and could seek to
suppress evidence found in the vehicle as the fruit of his illegal detention. Id. Because the
government conceded that the defendant’s continued detention had been unlawful, the only
issue on appeal was whether the narcotics found in the vehicle were the fruit of the
defendant’s illegal detention. Id. This was held to depend upon a showing of “a factual
nexus between his unlawful detention and the discovery” of the narcotics. Id. In order to
make such a showing, the DeLuca court held that it was incumbent upon the defendant to
adduce evidence demonstrating that the narcotics “would never have been found but for his,
and only his, unlawful detention.” Id. at 1133. In satisfaction of this requirement, the court
suggested that the defendant was required to demonstrate that “had he requested to leave the
scene of the traffic stop, he would have been able to do so” in the vehicle. Id. Without such
evidence, the DeLuca court majority opinion held that “we must assume that regardless of
[the defendant’s] presence, the car and its owner would have continued to be detained and
the officer would still have found the methamphetamine.” Id. Because the defendant failed
to present any evidence to rebut that presumption, the DeLuca court ultimately held that the
narcotics were not the fruit of the defendant’s illegal detention. Id. at 1133-34.

{29} Judge Seymour dissented from the DeLuca majority opinion on several grounds and
began her analysis by noting that “in vehicle stop cases[,] . . . once the occupants of the
vehicle have established that their detention, arrest or stop was illegal, as a general rule any
evidence obtained as a result of their detention must be excluded as fruit of the poisonous
tree.” Id. at 1137 (Seymour, J., dissenting) (internal quotation marks and citation omitted).
The dissent observed that the majority opinion relied on a flawed analysis in United States
v. Nava-Ramirez, 210 F.3d 1128 (10th Cir. 2000), which imposed a “heightened factual
nexus test” that was contrary to precedent. DeLuca, 269 F.3d at 1142, 1144 (Seymour, J.,
dissenting) (internal quotation marks omitted). According to the dissent, precedent requires
no such heightened nexus and “has simply assumed . . . that the factual nexus between the
illegal conduct and discovery of evidence in the car in such cases is crystal clear given the
proximity in time and in location of the events, and the unbroken links between them.” Id.
at 1144 (Seymour, J., dissenting).

{30} Judge Seymour further noted that, unlike the DeLuca majority opinion and Nava-
Ramirez, established precedent does not distinguish between a driver and a passenger when
determining whether the evidence is the fruit of the illegality. DeLuca, 269 F.3d at 1145
(Seymour, J., dissenting). Instead, “once the issue of standing has been resolved we have
conducted the fruits analysis in the exact same manner with respect to each type of
occupant,” whether driver or passenger. Id.

{31} Finally, Judge Seymour noted that Nava-Ramirez erroneously required a non-owner
driver to “attempt to remove the car from the scene in order to stop it from being illegally
searched before he is entitled to have evidence discovered in the trunk suppressed.” DeLuca,
269 F.3d at 1146-47 (Seymour, J., dissenting). In reliance on this flawed proposition in
Nava-Ramirez, the majority in DeLuca held that the passenger defendant had to establish
that he asked the detaining police officers if he could leave the scene of the traffic stop in the

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driver’s car before he could challenge the discovery of the evidence. 269 F.3d at 1133. The
dissent observed that this proposition is tantamount to saying that “because the illegal search
would have happened anyway, the evidence is admissible,” and such a notion is contrary to
precedent. Id. at 1147 (Seymour, J., dissenting). Judge Seymour further noted that “[u]nder
the heightened Nava-Ramirez fruits analysis, . . . while a non-owner driver and a passenger
may theoretically challenge their illegal detention, they will have no remedy because they
will be unable to satisfy the implausible Nava-Ramirez requirement that they prove they tried
to leave with the vehicle prior to the illegal search.” DeLuca, 269 F.3d at 1148 (Seymour,
J., dissenting).

{32} We believe Judge Seymour’s dissent provides the better view of this issue, and a
leading treatise agrees, stating:

It is unquestionably true, just as the dissent [in DeLuca] concludes, that the
DeLuca [majority’s] approach undermines the rationale for the exclusionary
rule; indeed, DeLuca provides positive encouragement for Fourth
Amendment violations by telling the police that there are potential law
enforcement benefits to be derived, at least against the passengers, in
extending lawful stops even when, as in DeLuca, such action is flagrantly
illegal.

6 Wayne R. LaFave, Search And Seizure: A Treatise On The Fourth Amendment § 11.4 (4th
ed. 2010) (internal quotation marks omitted) . Given the more expansive interpretation our
courts have given Article II, Section 10 of the State Constitution, we conclude in the present
case that the illegal detention of Defendant resulted in the discovery of the evidence in the
car. That discovery was fruit of the poisonous tree, and it was subject to suppression unless
the State demonstrated that the evidence was purged of its taint. See DeLuca, 269 F.3d at
1137-38 (Seymour, J., dissenting).

{33} We understand the State to suggest that Defendant’s consent to the search rendered
any preceding illegality immaterial. “In order for evidence obtained after an illegality, but
with the voluntary consent of the defendant, to be admissible, there must be a break in the
causal chain from the illegality to the search.” State v. Taylor, 1999-NMCA-022, ¶ 28, 126
N.M. 569, 973 P.2d 246 (alterations omitted) (internal quotation marks and citation omitted).
“In deciding whether the consent is sufficiently attenuated from the . . . violation, we
consider the temporal proximity of the illegal act and the consent, the presence or absence
of intervening circumstances, and the purpose and flagrancy of the official misconduct.” Id.
In this case, there was no attenuation whatsoever between the improper questioning and the
request for consent. Officer Thatcher asked the improper questions immediately before
seeking consent to search, and no other events occurred to separate the consent and the
questions. Moreover, the purpose of requesting consent to search was clearly to verify the
answers to the improper questions, thereby continuing an investigation that was beyond the
scope of reasonable suspicion. Under such circumstances, we conclude that Defendant’s

9
consent was not sufficiently attenuated from the illegality to remove its taint. See id. ¶ 29
(arriving at a similar conclusion under analogous circumstances).

{34} To the extent the State suggests that the driver’s consent overrode the illegality of
the detention, we are not persuaded. Both the driver and Defendant were illegally detained
by way of Officer Thatcher’s improper questioning, and the evidence was discovered as a
result of that detention. The driver’s consent did not purge the taint of that primary
illegality.

CONCLUSION

{35} For the foregoing reasons, we reverse the district court’s denial of Defendant’s
motion to suppress.

{36} IT IS SO ORDERED.

____________________________________
CYNTHIA A. FRY, Judge

WE CONCUR:

____________________________________
MICHAEL D. BUSTAMANTE, Judge

____________________________________
JONATHAN B. SUTIN, Judge

Topic Index for State v. Portillo, Docket No. 29,564

AE APPEAL AND ERROR
AE-SR Standard of Review

CT CONSTITUTIONAL LAW
CT-FA Fourth Amendment
CT-NM New Mexico Constitution, General
CT-SD Standing
CT-SU Suppression of Evidence

CL CRIMINAL LAW
CL-CL Controlled Substances
CL-MH Motor Vehicle Violations

CA CRIMINAL PROCEDURE
CA-DN Detention or Custody

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CA-MR Motion to Suppress
CA-RS Reasonable Suspicion
CA-SZ Search and Seizure
CA-SG Standing
CA-WS Warrantless Search

EV EVIDENCE
EV-SU Suppression of Evidence

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