State v. Ruiz-Espinosa

Under Article I, section 9, to show a defendant was unreasonably seized three standards must be met: (1) the state has the burden to establish that the officer acted lawfully; (2) the state must meet the Middleton test previously stated from the Defendant’s argument; and (3) the court must determine “whether the officer’s stated basis for extending the detention is objectively reasonable.”

Defendant appealed a conviction for possession of methamphetamine. Defendant assigned error to evidence being admitted after a denial of a motion to suppress. On appeal, Defendant argued that the police officer had detained him “for longer than was reasonably necessary to verify his identity.” The argument comes from State v Middleton, which states that an officer may only “continue to detain a person to establish that person’s identity . . . only if the officer can articulate facts reasonably establishing . . . that the individual’s not who he or she claims to be.” The state contended that it was lawful for the police officer to detain the Defendant if he was “’not satisfied’ about defendant’s identity based on specific, articulable facts.” Under Article I, section 9, to show a defendant was unreasonably seized three standards must be met: (1) the state has the burden to establish that the officer acted lawfully; (2) the state must meet the Middleton test previously stated from the Defendant’s argument; and (3) the court must determine “whether the officer’s stated basis for extending the detention is objectively reasonable.” The Court found that State did not meet the burden of proof, as the facts the officer gave were not enough to support reasonable suspicion. Reversed and remanded.