State v. Hinmon, 385 P.3d 751

Grocery store employee (identified, long‑time employee) observed a small green car backed into an employee parking area; passenger "lurched forward," covered his lap, and appeared to be twisting pink balloons on a towel.
Employee reported his suspicions of a possible drug transaction to the store manager and a security guard (Guard), who was a sworn peace officer working in uniform.
Guard approached, corroborated the vehicle description and passenger placement, and ordered the passenger (Hinmon) not to move; Hinmon shoved items from his lap toward the floor, yelled at the driver to "take off," and reached toward the gearshift.
Guard reached into the passenger window to restrain Hinmon, a struggle occurred, a pink balloon fell into the backseat, the manager retrieved it, and a field test later confirmed heroin.
Hinmon was charged with possession and interfering with an arrest; he moved to suppress the balloon and field‑test results as fruits of an unconstitutional search and seizure; the trial court denied suppression, finding Guard had reasonable suspicion for the stop and probable cause for the arrest.
Hinmon entered a conditional (Sery) plea preserving appeal of the suppression ruling; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (Hinmon)	Defendant's Argument (State/Guard)	Held
Whether Guard had reasonable suspicion to detain Hinmon	Employee's tip lacked adequate basis of knowledge and was insufficient to support a detention	Employee was an identified, uncompensated citizen informant who gave detailed, corroborated information; totality of circumstances supported reasonable suspicion	Court held Guard had reasonable suspicion to detain Hinmon
Whether Guard had probable cause to arrest Hinmon after detainment	Hinmon disputed the trial court's finding on the order of events and argued furtive movements alone did not provide probable cause	Hinmon's attempt to conceal items, commands to flee, and reaching for the gearshift—together with the tip and Guard's observations—created a fair probability of criminal activity	Court held Guard had probable cause to arrest Hinmon
Whether trial court's factual findings were clearly erroneous	Certain factual findings (order of statements/movements; Employee's claimed experience) were challenged as not supported by the record	Trial court credibility determinations were supported by testimony and record; appellate review defers unless findings are clearly erroneous	Court concluded the challenged findings were not clearly erroneous

Devenpeck v. Alford, 543 U.S. 146 (2004) (probable cause standard for arrests is based on facts known to the officer)
Illinois v. Gates, 462 U.S. 213 (1983) (totality‑of‑the‑circumstances test for probable cause)
Navarette v. California, 134 S. Ct. 1683 (2014) (reasonable suspicion depends on content and reliability of information)
Sibron v. New York, 392 U.S. 40 (1968) (furtive actions and flight may be considered in assessing mens rea and probable cause)
State v. Saddler, 104 P.3d 1265 (Utah 2004) (rejecting rigid three‑factor informant test in favor of a totality‑of‑circumstances approach)
State v. Roybal, 232 P.3d 1016 (Utah 2010) (identified citizen informant tips can supply reasonable suspicion)
State v. Hansen, 262 P.3d 448 (Utah Ct. App. 2011) (probable cause standard for warrantless arrests)
State v. Rose, 345 P.3d 757 (Utah Ct. App. 2015) (discussing three‑factor approach to citizen informant tips while acknowledging Saddler's totality approach)