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Keywords

defendanttrialpleamotionobjectionguilty plea

appealtrialmotionappellant

Related Cases

Davis v. Commonwealth, 484 S.W.3d 288

Facts

Defendant Thomas J. Davis entered a conditional guilty plea to trafficking in a controlled substance and other offenses after being stopped by Officer Tim McCoy for suspected DUI. During the stop, McCoy conducted field sobriety tests, which Davis passed, but then extended the stop to conduct a sniff search with his canine partner, Chico, despite Davis's objections. The search revealed illegal drugs, leading to Davis's arrest and subsequent guilty plea.

Officer Tim McCoy was on duty in the late evening hours, parked on the side of a remote gravel road in a rural area of McLean County, as he described it, “looking for DUI drivers.” Riding with McCoy that evening was his canine partner, Chico. McCoy was aware of allegations that Appellant was involved with illegal drugs.

Issue

Did the trial court err in denying the motion to suppress evidence obtained from a sniff search conducted after the lawful purpose of the traffic stop had been completed?

The issue preserved for appeal is the trial court's denial of Appellant's motion to suppress evidence that was found on his person and in his car following a sniff search by a narcotics-detection dog.

Rule

A traffic stop may not be extended beyond its original purpose without reasonable suspicion of further criminal activity, and any evidence obtained as a result of an unlawful extension of the stop is inadmissible.

“Although an officer may detain a vehicle and its occupants in order to conduct an ordinary traffic stop, ‘any subsequent detention … must not be excessively intrusive in that the officer's actions must be reasonably related in scope to circumstances justifying the initial interference.’”

Analysis

The court determined that Officer McCoy had completed the purpose of the traffic stop when Davis passed the field sobriety tests. The extension of the stop for a canine sniff search was deemed unlawful as there was no reasonable suspicion to justify the prolongation. The sniff search was unrelated to the original purpose of verifying sobriety, thus violating the defendant's Fourth Amendment rights.

The problem with this reasoning is that, in addition to passing two sobriety tests, no evidence suggests that Appellant's speech, demeanor, or behavior otherwise exhibited any characteristics associated with drug or alcohol intoxication from which an officer might reasonably believe further investigation was necessary.

Conclusion

The court reversed the McLean Circuit Court's judgment and remanded the case for further proceedings, ruling that the evidence obtained from the unlawful search should have been suppressed.

For the foregoing reasons, the evidence obtained against the Appellant as a result of the unlawful search should have been suppressed.

Who won?

Thomas J. Davis prevailed because the court found that the evidence obtained from the sniff search was inadmissible due to the unlawful extension of the traffic stop.

Appellant contends that the trial court erred in its application of the law to the facts which, in Appellant's view, compelled a conclusion that Chico's sniff search was illegal because it occurred after McCoy had accomplished the purpose of the traffic stop.

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