State v. Oller

If a traffic stop has ended, a police officer may only detain a suspect for further investigation if the detention is supported by reasonable suspicion.

Defendant appealed a judgment of conviction for unlawful possession of methamphetamine. Defendant assigned error to the trial court's denial of her motion to suppress evidence obtained in a renewed stop for which the officer did not have reasonable suspicion. The officer stopped Defendant for a traffic stop, and once the traffic stop concluded, Defendant was further detained to investigate potential drug crimes. A “renewed seizure” is lawful only if the circumstances support a reasonable suspicion that a defendant was engaged in criminal activity. “Reasonable suspicion” exists when an officer subjectively believes that a person has committed or is about to commit a crime and that belief is objectively reasonable in light of the totality of the circumstances existing at the time of the stop.” If reasonable suspicion is based upon “a chain of interlocking inferences,” the court must assess whether those inferences are individually and collectively reasonable. The Court held that the officer’s subjective belief was not reasonable because impermissible stacking of inferences, even though based on his training and experience, was all that connected the officer’s observations with the ultimate inference that Defendant possessed drugs. The renewed stop was not based on reasonable suspicion. Reversed and remanded.