People v. Guthrie
2012 CO 59
Colo.2012Background
- Guthrie was summoned for a DUI offense and, after plea discussions, was escorted to arrange an alcohol evaluation.
- A clerk detected alcohol on Guthrie’s breath; a probation office report led the county court to order Guthrie jailed for indirect contempt.
- A deputy sheriff arrested Guthrie and conducted an inventory of her purse before placing her in a holding cell, during which oxycodone was found without a prescription.
- Guthrie faced a felony charge for possession of a Schedule II controlled substance, and moved to suppress the inventory-search evidence.
- The district court suppressed the evidence as an ad hoc remedy for a claimed due-process violation by the contempt proceeding, holding the deputy acted in good faith.
- The prosecution appealed; the court reverses, holding no Fourth Amendment violation occurred and suppression was not an appropriate remedy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Fourth Amendment was violated by the inventory search. | Prosecution argues suppression is improper and no violation occurred. | Guthrie argues due-process concerns could justify suppression of the fruits. | No Fourth Amendment violation; inventory search valid. |
| Whether suppression was the proper remedy for the alleged due-process error in the contempt order. | Prosecution contends suppression was improper remedy; evidence should be admitted. | Guthrie contends the district court’s remedy was appropriate for due-process violation. | Suppression was not a proper remedy; reversed. |
| What is the proper standard of review for suppression orders in this context? | Prosecution argues deferential review of factual findings and de novo on law. | Guthrie accepts standard review framework recognizing the same. | Deference to factual findings with de novo review of legal standards. |
Key Cases Cited
- Lafayette v. United States, 462 U.S. 640 (U.S. Supreme Court, 1983) (inventory searches as routine procedure incident to arrest and jail)
- Bertine, 479 U.S. 367 (U.S. Supreme Court, 1987) (inventory search validity; standardized procedures; no bad faith)
- Inman, 765 P.2d 577 (Colo. Supreme Court, 1988) (inventory search of purse during booking reasonable)
- Robinson, 683 A.2d 1007 (Vt. 1996) (inventory search post-contempt context not subject to suppression)
- Aleem, 149 P.3d 765 (Colo. 2007) (procedure for reviewing summary contempt; rights of contemnor)
- Gutierrez, 222 P.3d 925 (Colo. 2009) (exclusionary rule limited to deter unlawful search)