State of Arizona v. Nelson Ivan Boteo-Flores, 230 Ariz. 105

Police surveilled a stolen black pickup truck at an apartment complex and observed related suspicious activity by a maroon car.
Boteo-Flores walked near the driveway; the truck driver later shouted to him as officers pursued the vehicle.
Boteo-Flores was handcuffed during the ongoing investigation due to safety concerns about unknown occupants and potential armed status.
After handcuffing, officers gave Miranda warnings and questioned Boteo-Flores; a detective later joined and questioned him, leading to an arrest based on admissions.
A suppression motion was denied; trial court convicted Boteo-Flores of facilitating theft of a means of transportation; appellate courts upheld, then the Arizona Supreme Court granted review to address de facto arrest.
The Supreme Court vacated the appellate decision and remanded to determine whether the stop became a de facto arrest and how suppression and attenuation of a confession should be handled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop had reasonable suspicion	State argues stop was supported by reasonable suspicion.	Boteo-Flores contends lack of reasonable suspicion.	Yes; reasonable suspicion existed to justify the stop.
Whether extended handcuffing and waiting for a detective transformed the stop into a de facto arrest	State contends continued detention was necessary for safety and investigation.	Boteo-Flores argues continued handcuffing and delay rendered it an arrest.	Yes; the continued handcuffing and delay was a de facto arrest before interrogation.
Whether there was probable cause to arrest before the confession	State contends no probable cause existed until after confession, but detention could be justified as a stop.	Boteo-Flores argues arrest without probable cause was unlawful.	No probable cause existed prior to the confession.
Whether the confession is admissible despite the de facto arrest, and attenuation	State argues confession should be admissible if attenuated from unlawful arrest.	Boteo-Flores argues taint from unlawful arrest requires suppression.	Remanded for appellate consideration of attenuation and suppression issues.

Terry v. Ohio, 392 U.S. 1 (392 U.S. 1 (1968)) (establishes permissibility of brief investigative detentions with reasonable suspicion)
State v. Blackmore, 186 Ariz. 630 (1996) (limits and context for handcuffing during a Terry stop)
State v. O’Meara, 198 Ariz. 294 (2000) (reasonable suspicion standard for stops; totality of circumstances)
United States v. Sharpe, 470 U.S. 675 (1985) (no rigid time limit for Terry stops; reasonableness of detention duration)
Florida v. Royer, 460 U.S. 491 (1983) (investigative seizure must be limited in scope and duration)
State v. Spreitz, 190 Ariz. 129 (1997) (context of reasonable investigation duration under unusual circumstances)
Brown v. Illinois, 422 U.S. 590 (1975) (whether a confession may purge taint from an unlawful arrest)
State v. Reffitt, 145 Ariz. 452 (1985) (attentuation principle for tainted confessions)