State v. Martinez
293 P.3d 718
| Kan. | 2013Background
- Martinez challenges the district court’s denial of his motion to suppress cocaine found during a routine search after a stop.
- Officers attempted to serve a felony arrest warrant on Aguirre, who had moved or been located at a complex.
- Officers observed Martinez driving a Mustang connected to Aguirre and believed Aguirre’s whereabouts were likely known to Martinez.
- Police stopped Martinez with a show of authority (sirens/weapon, commanding tone) and Martinez submitted to the stop.
- Aguirre was seen in the back seat of Martinez’s car, and Martinez was arrested for obstructing legal process; cocaine was found during a search.
- A district court denied suppression, relying on Finley to justify the stop; the Court of Appeals affirmed, and the Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion to justify the Terry stop of Martinez? | Martinez: no factual basis showing crime imminent. | Martinez: officers' hunch, view of Aguirre, and situational factors suffice under totality of circumstances. | No reasonable suspicion; suppression reversed. |
| Did evidence obtained as a result of the stop (cocaine) have to be suppressed? | Evidence derives from an unlawful seizure. | Evidence admissible if stop was lawful. | Yes; cocaine should be suppressed. |
Key Cases Cited
- State v. Morris, 276 Kan. 11 (2003) (reasonable suspicion framework)
- State v. Parker, 282 Kan. 584 (2006) (totality of circumstances; trained officer perspective)
- State v. DeMarco, 263 Kan. 727 (1998) (reasonable suspicion standard; common sense approach)
- United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion standard; totality of circumstances)
- State v. Weaver, 259 Kan. 844 (1996) (seizure occurs upon submission to show of authority)
- State v. Walker, 292 Kan. 1 (2011) (investigatory stop when multiple officers, weapon, and command present)
- State v. Johnson, 293 Kan. 1 (2011) (burden on State; suppression standard)
- State v. Finley, 17 Kan. App. 2d 246 (1992) (earlier rule permitting stop under certain circumstances)