Colorado v. Funez-Paiagua

The State filed an interlocutory appeal of a trial court's suppression of evidence obtained following an investigatory stop of Defendant Adolph Funez-Paiagua. Defendant was standing on the property of a closed auto-body shop at 1:15 in the morning. One of two responding officers approached where Defendant had been standing. After hearing a loud crash and seeing Defendant fleeing the property with "some large bags," the officer ordered Defendant to stop. The trial court found the officer's testimony credible, but concluded that the evidence did not establish reasonable suspicion to justify the investigatory stop. Specifically, the trial court determined that the seizure occurred "at the time the [first] officer contacted [Funez-Paiagua]." The trial court found that, at that time, the officer knew that Defendant was standing on private property late at night. The trial court concluded that these facts did not support reasonable suspicion to justify the investigatory stop and therefore the trial court suppressed the evidence seized as a result of the stop. Upon review, the Supreme Court concluded that the totality of the circumstances known to the officers at the time of the stop created reasonable suspicion. The investigatory stop was therefore not an unreasonable seizure, and the trial court incorrectly suppressed evidence resulting from the stop. View "Colorado v. Funez-Paiagua" on Justia Law