State v. Maciel

An officer has reasonable suspicion to stop a person when the officer subjectively believes the person has committed a crime and that belief is objectively reasonable in the totality of the circumstances. Reasonable suspicion must be based on specific articulable facts of the crime suspected to be objectively reasonable.

Defendant pleaded no-contest to possession of methamphetamine after the trial court denied Defendant’s motion to suppress. Defendant was a passenger in a car stopped for speeding. The driver’s license did not match the vehicle’s registration or insurance, and driver and Defendant denied owning the vehicle. Defendant claimed he purchased the vehicle in California, though he had no documents of a sale, had not settled on a purchase price with the seller, did not have seller’s phone number, and said he was conducting a test drive from Oakland, CA to Woodburn, OR. A dog sniff uncovered methamphetamine. Reasonable suspicion must be based on specific articulable facts of the crime suspected to be objectively reasonable. Here, the Court of Appeals held that police lacked reasonable suspicion to extend the stop to drug trafficking, as opposed to a stolen vehicle, because inferences were too speculative because indicators such as pre-paid cellular phones, California plates, and third-party vehicles were insufficient to establish reasonable suspicion of drug trafficking. Reversed and remanded.