State v. Maciel-Figueroa

An officer has reasonable suspicion for a lawful investigatory stop when “an officer can point to specific and articulable facts that give rise to a reasonable inference that the defendant committed or was about to commit a specific crime or type of crime.”

The State petitioned for review of the Court of Appeals' opinion that reversed the trial court's denial of Defendant's motion to suppress. At the trial court, Defendant moved to suppress evidence found after a search on the grounds that the officers lacked reasonable suspicion. The trial court denied the motion because the officers’ “suspicion was objectively reasonable to stop the defendant to investigate whether a crime has been committed.” The Court of Appeals reversed and held “the facts known to the officers at the time of the stop…were not sufficient to support an objectively reasonable conclusion that a crime had occurred.” The State petitioned for review on the grounds that the Court of Appeals heightened the standard of reasonable suspicion and proffered reasonable suspicion exists “if the officer reasonably believes that the person was either somehow involved with, or a witness to, possible criminal activity.” Reasonable suspicion is an “objective test based on observable facts” that are available at the time of a stop, not an officer’s intuition. State v. Holdorf, 355 Or 812, 822-23 (2014). The Court held (1) an officer has reasonable suspicion for a lawful investigatory stop when “an officer can point to specific and articulable facts that give rise to a reasonable inference that the defendant committed or was about to commit a specific crime or type of crime”; and (2) based on the the facts given in trial court record, the officers lacked reasonable suspicion because the record did not contain sufficient articulable facts that could be objectively evaluated. The decision of the Court of Appeals is affirmed. The judgment of the circuit court is reversed, and the case is remanded to the circuit court for further proceedings.