People v. Coates
266 P.3d 397
| Colo. | 2011Background
- The People appealed an order suppressing trunk-seized evidence from Coates's vehicle after a stop and arrest of the driver.
- A bindle with a single Xanax pill was found on the driver; a trunk of the vehicle contained prescription pills.
- The district court found no reasonable basis to search the trunk incident to arrest and no probable cause for a warrantless trunk search.
- The arresting officer testified; the driver was a minor with no license; both passengers later claimed ownership but denied knowledge of trunk pills.
- The court analyzed the search under search-incident-to-arrest and automobile-exception doctrines in light of Arizona v. Gant.
- This Court upheld suppression of the trunk evidence, ruling no probable cause or valid basis justified a trunk search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trunk search was valid | People: there was probable cause or valid exception to search the trunk. | Coates: no probable cause or valid basis for trunk search. | Suppression affirmed; no probable cause or valid search basis for trunk. |
| Effect of Gant on scope of search | People rely on Gant to justify broader searches for evidence of the arrest crime. | Coates: Gant allows only passenger-compartment searches with reasonable suspicion. | Gant limitations apply; trunk search not justified under any prong. |
| Adequacy of probable cause for vehicle search | People contend circumstances produced probable cause to search the vehicle. | Coates contends no fair probability of contraband; driver’s nervousness insufficient. | No probable cause established; trunk search unlawful. |
Key Cases Cited
- Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (limits search-incident-to-arrest to passenger compartment absent other justification)
- People v. Chamberlain, 229 P.3d 1054 (Colo. 2010) (reasonableness standard for evidentiary searches after Gant)
- People v. McCarty, 229 P.3d 1041 (Colo. 2010) (reiterates Gant framework in Colorado context)
- Perez v. People, 231 P.3d 957 (Colo. 2010) (applies Gant-based analysis to Colorado offenses)
- People v. Crippen, 223 P.3d 114 (Colo. 2010) (probable cause as a totality-of-the-circumstances test)
- Wyoming v. Houghton, 526 U.S. 295 (U.S. 1999) (automobile exception scope and probable cause principles)