Salt Lake City v. Hughes, 253 P.3d 1118

Defendant Hughes appeals a Sery plea to several class B misdemeanors following a stop alleging unlawful seizure.
At 2:30 a.m. in winter conditions, an officer observed Hughes sprinting in the middle of a street and crossing State Street outside a crosswalk.
Hughes then entered a bank parking lot, and the officer stopped him, relying on a jaywalking observation.
Hughes argued the stop was not justified at inception and challenged credibility of the officer, not the scope of detention.
The trial court denied the suppression motion, concluding the stop was justified under reasonable suspicion; the court’s credibility assessment favored the officer’s testimony.
The Utah Court of Appeals affirmed, holding the stop was supported by reasonable suspicion and that credibility determinations are within the trial court’s province.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion	Hughes argues the stop lacked reasonable suspicion	Hughes contends credibility issues do not negate lack of suspicion	Stop supported by reasonable suspicion

State v. Markland, 112 P.3d 507 (2005 UT 26) (detention permissible with reasonable, articulable suspicion)
State v. Lopez, 873 P.2d 1127 (Utah 1994) (stop when traffic violation observed in officer's presence)
State v. Worwood, 164 P.3d 397 (2007 UT 47) (objective reasonable-suspicion standard governs stop)
State v. Brake, 103 P.3d 699 (2004 UT 95) (legal framework for reviewing suppression rulings)
State v. Krukowski, 100 P.3d 1222 (2004 UT 94) (clear-error standard for factual findings on suppression)
State v. Hansen, 63 P.3d 650 (2002 UT 125) (credibility of witnesses within trial court’s province)