People v. Steele
201 Cal. Rptr. 3d 363
Cal. Ct. App.2016Background
- Shortly after 10:00 p.m., two deputies in a marked patrol car followed two vehicles onto a dark, rural dead-end driveway; the lead vehicle had expired registration and the second was driven by Steele.
- Dispatch advised deputies there was a felony arrest warrant for the registered owner of the lead vehicle; deputies decided to stop the lead vehicle for expired registration and the warrant.
- The patrol car pulled into the driveway and stopped behind Steele’s parked vehicle with emergency lights activated; deputies approached Steele’s vehicle first for officer-safety reasons.
- On approach the deputy smelled marijuana, saw marijuana in plain view on the backseat, and after asking Steele to exit located marijuana and methamphetamine during a search.
- Steele moved to suppress the evidence arguing the deputies’ initial contact was an unlawful detention without reasonable suspicion; the trial court denied suppression, Steele pleaded no contest, and was sentenced to six years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether initial contact was a consensual encounter or a detention | People: Contact was consensual or, if a seizure, justified by probable cause to stop lead vehicle and officer safety | Steele: Deputies’ parking behind his car with lights on constituted a detention requiring reasonable suspicion specific to him | Court: The show of authority (park behind + lights) constituted a detention under Brown; Steele was therefore seized |
| Whether deputies had legal justification to detain Steele | People: Officer-safety and the need to effectuate a lawful stop of the lead vehicle justified a brief detention of Steele without individualized suspicion | Steele: Deputies lacked reasonable suspicion as to him and thus detention was unlawful | Court: Balancing interests (Glaser, Maryland v. Wilson, Taylor) — the brief detention was reasonable and necessary for officer safety while deputies investigated the lead vehicle |
| Whether evidence discovered after contact should be suppressed | People: Once deputies smelled marijuana and observed it in plain view, they had cause to search and seize evidence | Steele: Evidence is fruit of an unlawful detention and should be suppressed | Court: Because initial detention was lawful and deputies obtained probable cause (odor/plain view), evidence admissible |
Key Cases Cited
- People v. Brown, 61 Cal.4th 968 (Cal. 2015) (parking behind a parked car and activating lights is a show of authority constituting a detention)
- People v. Glaser, 11 Cal.4th 354 (Cal. 1995) (brief detention near execution of warrant is reasonable to ensure officer safety and determine connection to premises)
- Maryland v. Wilson, 519 U.S. 408 (U.S. 1997) (officer safety justifies ordering passengers from a lawfully stopped vehicle)
- Michigan v. Summers, 452 U.S. 692 (U.S. 1981) (detaining occupants during execution of a search warrant is reasonable to minimize risk to officers)
- People v. Taylor, 41 P.3d 681 (Colo. 2002) (stopping a vehicle to effect arrest of a passenger can be reasonable despite lack of individualized suspicion as to driver)