263 P.3d 463
Utah Ct. App.2011Background
- Butler was stopped for alleged minor traffic violation (failure to signal) observed as he pulled away from curb.
- Agent Beck had a confidential informant (CI) tip identifying a green Dodge truck with a hidden drug compartment.
- CI provided address and asserted drugs (about ten grams of meth) would be transported in the driver’s door panel.
- Beck and Burrell located the address; Beck recognized it as a suspected drug residence and observed Butler’s truck at the address.
- Butler left the residence, pulled away without signaling, and the CI advised that drugs remained in the truck.
- Officer Conners initiated the stop based on Beck’s determination of reasonable suspicion and observed traffic violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the traffic stop constitutional? | Butler | Butler | Yes; stop valid for minor violation |
| Was the stop justified by reasonable suspicion of drug activity? | Beck had reasonable suspicion from CI tip and corroboration | Butler challenges credibility/weight | Yes; totality of circumstances supported suspicion |
| Was the arrest constitutionally valid given probable cause? | Probable cause existed from drug activity evidence | Arrest based on flawed stop | Yes; probable cause to detain/arrest Butler |
| Was the search of Butler's truck valid under the automobile exception? | Truck readily mobile; probable cause to believe contraband inside | No exigency or warrantless search justification | Yes; automobile exception applied |
Key Cases Cited
- State v. Applegate, 194 P.3d 925 (Utah 2008) (clarifies standard for reviewing suppression rulings; totality of circumstances)
- State v. Worwood, 164 P.3d 397 (Utah 2007) (Fourth Amendment mixed questions reviewed for correctness)
- State v. Despain, 173 P.3d 213 (Utah App. 2007) (totality of circumstances in probable cause and stop analysis)
- State v. Humphrey, 937 P.2d 137 (Utah Ct. App. 1997) (reasonableness of stops under totality of circumstances)
- State v. Roybal, 232 P.3d 1016 (Utah 2010) (reliance on other information sources in stop justification)
- State v. Trane, 57 P.3d 1052 (Utah 2002) (probable cause standard for warrantless arrests)
- Maryland v. Dyson, 527 U.S. 465 (U.S. 2000) (automobile exception and its scope)
- Wyoming v. Houghton, 526 U.S. 295 (U.S. 1999) (contents within a vehicle may be searched under automobile exception)