People v. Castaneda
249 P.3d 1119
Colo.2011Background
- Castaneda was charged with possession of a schedule II substance found during a search of her vehicle after a hit-and-run and DUI.
- At the roadside, Castaneda claimed a six-foot-tall woman named Jowanna drove the car and she had not driven it.
- The arresting officer observed the driver's seat was positioned too far forward for a six-foot driver and detected alcohol on Castaneda’s breath.
- The trial court suppressed the evidence, ruling there was no probable cause to arrest Castaneda as the driver.
- The Colorado Supreme Court reversed, holding the totality of circumstances supported probable cause that Castaneda drove the vehicle and left the scene.
- Evidence later admitted at trial would be admissible if the arrest was supported by probable cause; the case was remanded for proceedings consistent with this opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there probable cause to arrest Castaneda as the driver? | Probable cause existed from totality: matched plates, seat position, odor of alcohol, and Castaneda’s unique link to the scene. | Facts could support innocent explanations; cannot show Castaneda drove. | Yes; totality supported probable cause to arrest as driver. |
Key Cases Cited
- People v. McClain, 149 P.3d 787 (Colo.2007) (standard for reviewing suppression rulings; factual findings deferential, legal ruling de novo)
- People v. Syrie, 101 P.3d 219 (Colo.2004) (probable cause analysis under totality-of-circumstances)
- People v. Washington, 865 P.2d 145 (Colo.1994) (probable cause and warrantless arrests; burden on prosecution)
- People v. Robinson, 226 P.3d 1145 (Colo.App.2009) (evidence from arrest admissible if arrest was supported by probable cause)
- People v. Diaz, 793 P.2d 1181 (Colo.1990) (totality-of-circumstances analysis for probable cause)