State v. Huerta-Contreras

A warrantless arrest is permissible when “the arresting officer has probable cause to believe that the person has committed a crime.”

Defendant appealed his conviction for unauthorized use of a vehicle (UUV) because the trial court denied his motion to suppress evidence. The defendant argued that the officer had no probable cause to arrest him. A warrantless arrest is permissible when “the arresting officer has probable cause to believe that the person has committed a crime.” The Court found that the officer found no suspicious conduct beyond the defendant sitting in the driver’s seat of the stolen car late at night. The Court reasoned that that was not enough for the officer to infer that the defendant possessed the requisite mental state. It was merely a hunch rather than probable cause. The Court held that it was not objectively reasonable under the totality of the circumstances for the officer to believe that, more likely than not, the defendant had committed UUV and that the officer did not have PC to arrest the defendant when he did. Reversed and remanded.