State v. Anderson
2013 UT App 272
| Utah Ct. App. | 2013Background
- Sergeant Robinson, a Major Crimes unit member, conducted narcotics interdiction training and surveillance activities for years.
- Major Crimes had a known history of drug activity at a gas station parking lot where they conducted controlled buys and observed suspects.
- On April 27, 2010, Robinson and two colleagues surveilled the gas station, observing Anderson arrive, park away from the store, and wait about ten minutes.
- Anderson exited her car, approached another vehicle, and engaged in a brief hand-to-hand exchange, then placed a small item into her pocket and left.
- Robinson, based on training and experience, believed the exchange matched patterns of a drug transaction and detained Anderson without a traffic violation in view, to investigate.
- During the stop, Anderson produced seven pills and a small bag; the bag contained methamphetamine; pills included suspected oxycodone without valid prescription; money was recovered from her planner during inventory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was reasonable, articulable suspicion to detain. | Anderson argues no reasonable suspicion. | Robinson's training and observations constitute reasonable suspicion. | Yes; totality of circumstances supported reasonable suspicion. |
Key Cases Cited
- State v. Gurule, 2013 UT 58 ( Utah (2013)) (standard of review for suppression findings; legality of stop analyzed)
- State v. Singleton, 2005 UT App 464 ( Utah App. 2005) (totality of circumstances and reasonable suspicion; deference to officer's discernment)
- State v. Applegate, 2008 UT 63 ( Utah (2008)) (reasonable suspicion may rely on officer's training; may include innocent explanations)
- State v. Alverez, 2006 UT 61 ( Utah (2006)) (totality of circumstances and reasonable suspicion framework)
- State v. Beach, 2002 UT App 160 ( Utah App. 2002) (hand-to-hand exchange in known drug activity area can support suspicion)