State v. Ellis, 287 P.3d 1215

Portland police stopped defendant after a FLIR-assisted surveillance operation suspecting a car prowl.
Officers observed defendant near a van, entering it briefly, and later moving toward dumpsters.
Detectives relied on pre-stop observations and dumpster-caching hypotheses to justify the stop.
Defendant was questioned, arrested for unlawful use of a motor vehicle, and a backpack search yielded incriminating items.
Trial court suppressed all evidence as stemming from an unlawful stop; the State appealed.
Appellate court reversed and remanded for reconsideration under correct legal standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop supported by reasonable suspicion?	State argues suspicion was objectively reasonable	Defendant argues lack of objective basis for suspicion	Yes or no: Reversed? The court held the stop was not properly analyzed under correct legal framework and remanded.
May evidence from backpack be admissible if stop unlawful?	State would argue consent/independent basis	Defendant argues suppression should apply to all derivative evidence	Remand to apply correct legal test; not decided on merits here.

State v. Belt, 325 Or 6, 932 P2d 1177 (1997) (Oregon Supreme Court 1997) (reasonable suspicion requires objective basis)
State v. Rutledge, 243 Or App 603, 260 P3d 532 (2011) (Or App 2011) (objective reasonable suspicion tied to specific facts and experience)
State v. Hammonds/Deschler, 155 Or App 622, 964 P2d 1094 (1998) (Or App 1998) (possible lawful explanations do not negate suspicion)
State v. Nguyen, 229 Or App 719, 212 P3d 1284 (2009) (Or App 2009) (suspicion evaluated under totality of circumstances)
State v. Ehret, 184 Or App 1, 55 P3d 512 (2002) (Or App 2002) (totality of circumstances governs reasonable suspicion)
State v. Stevens, 311 Or 119, 806 P2d 92 (1991) (Oregon Supreme Court 1991) (standard for applying factual findings to legal principles)