People v. Walker
210 Cal. App. 4th 1372
| Cal. Ct. App. | 2012Background
- Walker, a Black male, was detained at a San Jose light-rail station by Deputy Thrall after Thrall suspected he resembled a sexual-battery suspect from the prior week.
- Thrall asked for fare proof; Walker produced ID that belonged to someone else and was arrested after Thrall learned the ID was false.
- A search incident to arrest yielded cocaine base and marijuana.
- Walker pleaded guilty to counts on probation with imposition suspended; probation was later granted.
- Walker moved to suppress under Penal Code 1538.5; the trial court denied the motion and the plea proceeded.
- The appellate court held Thrall lacked a reasonable and articulable suspicion to detain and reversed the probation order and remanded with directions to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Thrall's detention supported by reasonable suspicion? | People argued totality of circumstances showed suspicion. | Walker argued detention was pretextual and based on race/appearance. | No; detention invalid for lack of reasonable suspicion. |
| Could the detention be justified by fare-check authority? | People relied on authority to stop fare evaders. | Walker contends the stop was a pretext for investigating the sex crime. | No; fare check justification cannot validate a pretextual stop. |
| Should evidence be suppressed due to unlawful detention and arrest? | N/A | N/A | Yes; suppression required, leading to dismissal. |
| Did reliance on resemblance to suspects and station/area support suspicion? | People relied on resemblance and location as factors. | Walker contends resemblance was insufficient; station timing attenuated relevance. | No; these factors did not establish objective reasonable suspicion. |
Key Cases Cited
- In re Tony C., 21 Cal.3d 888 (Cal. 1978) (establishes totality-of-circumstances approach to detentions)
- United States v. Cortez, 449 U.S. 411 (U.S. 1981) (reasonableness based on totality of circumstances)
- People v. Souza, 9 Cal.4th 224 (Cal. 1994) (defines reasonable-suspicion standard and its limits)
- Williams v. Superior Court, 168 Cal.App.3d 349 (Cal. App. 1985) (photos/descriptions not sufficient for suspicion; concerns about racial profiling)
- Durazo, 124 Cal.App.4th 728 (Cal. App. 2004) (attenuation of prior-crime nexus in detention analysis)
- People v. Bower, 24 Cal.3d 638 (Cal. 1979) (limits on using race to justify detention; pre-proposition 8 context)