This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
On May 13, 2007, a concerned citizen reported to dispatch that three intoxicated men, one of whom had been involved in a fight, left a convenience store in a silver Ford Taurus. Deputy Parsons responded to the dispatch and, after speaking with two witnesses at the store, located the vehicle a mile or two away. Without observing any erratic driving, the deputy stopped the vehicle and investigated the driver, who was later charged with driving under the influence.
Procedural History
- District Court, December 6, 2007: Denied the Defendant’s motion to suppress evidence, finding that the information provided by the caller and witnesses satisfied the reasonable suspicion standard for the stop.
Parties' Submissions
- Defendant-Appellant: Argued that Deputy Parsons lacked reasonable suspicion to stop the vehicle, violating the Fourth Amendment. Alternatively, claimed a violation of the Confrontation Clause due to the inability to confront the primary accuser, the citizen who reported the incident.
- Plaintiff-Appellee: Asserted that the stop was justified based on the totality of the circumstances, including the reliability of the identified caller and corroboration by two witnesses. Also argued that the Confrontation Clause does not apply to suppression hearings.
Legal Issues
- Did Deputy Parsons have reasonable suspicion to stop the Defendant’s vehicle under the Fourth Amendment?
- Was the Defendant’s right to confront his accuser violated under the Confrontation Clause?
Disposition
- The Court of Appeals affirmed the district court’s decision, holding that the stop was supported by reasonable suspicion and that the Confrontation Clause does not apply to suppression hearings.
Reasons
Per Wechsler J. (Robles and Garcia JJ. concurring):
The Court found that the stop was supported by reasonable suspicion based on the totality of the circumstances. The caller, an identified concerned citizen, personally observed the intoxicated individuals and their vehicle, which was corroborated by two additional witnesses at the convenience store. The information provided was sufficiently detailed to allow Deputy Parsons to locate the vehicle. The Court emphasized the exigency of the potential threat to public safety posed by a drunk driver, distinguishing this case from Florida v. J.L., which involved an uncorroborated anonymous tip.
Regarding the Confrontation Clause, the Court held that the Defendant failed to preserve this argument at the district court level. Additionally, it reiterated that the Confrontation Clause does not extend to suppression hearings, as established in prior case law.