This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Police officers were investigating a hit-and-run accident involving a silver Mustang driven by an individual on probation. The officers received information that the probationer's girlfriend, a probation absconder, might return to a motel driving the same car. The Defendant, matching the girlfriend's description, arrived at the motel in the Mustang. After confirming her identity through her driver’s license and further verification, officers detained her for an additional 10-15 minutes to conduct a warrants check, which revealed an outstanding misdemeanor warrant. During her arrest, officers discovered methamphetamine and a pipe.
Procedural History
- District Court, Albert “Pat” S. Murdoch, J.: Denied the Defendant’s motion to suppress evidence obtained during her detention.
Parties' Submissions
- Defendant-Appellant: Argued that the officers’ continued detention to conduct a warrants check after confirming she was not the probation absconder was improper and violated her rights.
- Plaintiff-Appellee: Contended that the continued detention was reasonable given the ongoing investigation into the hit-and-run accident and the circumstances surrounding the Defendant’s arrival in the vehicle involved.
Legal Issues
- Was the continued detention of the Defendant to conduct a warrants check after confirming her identity reasonable under the circumstances?
Disposition
- The Court of Appeals affirmed the district court’s denial of the Defendant’s motion to suppress evidence.
Reasons
Per Sutin J. (Fry C.J. and Castillo J. concurring):
The Court reviewed the denial of the motion to suppress as a mixed question of law and fact, applying the substantial evidence standard to the facts and conducting a de novo review of the legal application. The Court found that the initial detention was justified based on reasonable suspicion that the Defendant was the probation absconder. Although this suspicion was dispelled upon verification of her identity, the officers had additional grounds to investigate due to the ongoing hit-and-run investigation. The Defendant’s arrival in the vehicle involved in the accident created a reasonable basis to detain her briefly for further inquiry, including the warrants check. The Court concluded that the 10-15 minute detention was reasonable under the circumstances and affirmed the district court’s decision.