State v. Martinez

A trial court must make specific findings on the record that reasonable suspicion particular to the suspect existed when denying a criminal defendant's motion to suppress evidence that may have been gained after an unlawful seizure.

Defendant appealed two convictions for drug-related offenses arguing that the trial court erred by denying his motion to suppress incriminating statements. Defendant was a passenger in a vehicle that was stopped based on information that the vehicle contained drugs. At the stop, officer smelled marijuana, and called for a drug detection dog. While waiting, Defendant made incriminating statements to the officer, and when the dog arrived and alerted to the presence of drugs, the vehicle was searched, revealing methamphetamine, marijuana, and drug paraphernalia. Defendant moved to suppress the incriminating statements, arguing that they were elicited after an unlawful seizure. The State responded that the search of the van was permissible under the “automobile exception”. The trial court agreed with the State, but failed to address whether Defendant’s particular seizure was justified by reasonable suspicion. On appeal, Defendant argued that the officer had no reasonable suspicion particular to Defendant, and thus his incriminating statements warranted suppression. The Court held that, while the officer may have had reasonable suspicion based on a totality of the circumstances available at the time of the seizure, the trial court failed to make such findings on the record. The Court vacated the judgment, and remanded for the trial court to make findings specific to whether the officer had reasonable suspicion to seize Defendant.