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Unlawful Detention Results in Reversal

California v. Suggs Court: California Courts of Appeal, Docket: C096555 (Third Appellate District), Opinion Date: July 31, 2023. Defendant Anterion Suggs appeals a judgment following entry of a plea of no contest to misdemeanor possession of a concealed firearm after the trial court denied his motion to suppress evidence of the firearm and methamphetamine found in his vehicle. On appeal, Defendant contended the trial court erred in denying his motion to suppress, because the detention was unlawfully prolonged. Specifically, defendant claimed that once the arresting officer noticed the proper documentation attached to his vehicle’s rear window and thus learned that the reason he had stopped defendant was invalid, any further detention was unlawful. After review of the trial court record, the Court of Appeal concurred: the detention became unlawful when: (1) the purpose of the stop completely dissipated (when the officer saw the documents in the window and thus realized that defendant had not committed the Vehicle Code violation that was the purpose of the stop); and (2) the officer then made inquiries aimed at finding evidence of ordinary criminal wrongdoing. The judgment was reversed, the conviction was vacated, and the matter was remanded for the trial court to enter a new order granting that motion.

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