State v. Murphy
1 CA-CR 15-0806
| Ariz. Ct. App. | Feb 28, 2017Background
- Officers responded to an incident in Phoenix, pulled Murphy from a car, and searched the vehicle without a warrant because they were concerned someone might be hiding inside; they discovered a rifle in the trunk.
- Murphy was charged with misconduct involving weapons and unlawful use of means of transportation; he was later acquitted of the transportation count and convicted of weapons misconduct.
- At the suppression hearing the court focused on Murphy's Fourth Amendment standing to challenge the vehicle search.
- The State presented officer testimony that Murphy twice admitted the car was stolen (once at the scene, again days later) and introduced an affidavit from Murphy's girlfriend reporting the car stolen. Murphy presented no evidence.
- The superior court found (1) the car had been reported stolen, (2) Murphy’s later admission equated to abandonment/lack of possessory interest, and (3) officers acted in good-faith reliance on a belief they could open the trunk; it denied the motion to suppress.
- On appeal Murphy argued the acquittal on the theft-related charge undermined the standing finding; the Court of Appeals affirmed the denial of suppression and the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Murphy had Fourth Amendment standing to challenge the warrantless search of the car | The acquittal on the transportation/ theft-related charge shows he retained an interest in the car and thus standing | The State argued evidence (Murphy's admissions and girlfriend's stolen-vehicle affidavit) showed Murphy lacked a possessory interest and thus no standing | Court held Murphy lacked standing: State met preponderance burden at suppression hearing (admissions + affidavit); denial of suppression affirmed |
Key Cases Cited
- Rakas v. Illinois, 439 U.S. 128 (defendant must show a personal Fourth Amendment interest to challenge a search)
- State v. Berryman, 178 Ariz. 617 (appellate review standard for factual findings after suppression hearing)
- State v. Garcia, 224 Ariz. 1 (abuse of discretion standard for evidentiary rulings)
- State v. Newell, 212 Ariz. 389 (review of suppression rulings limited to suppression-hearing evidence)
- State v. Carreon, 210 Ariz. 54 (distinguishing burdens of proof at suppression hearing and at trial)
- United States v. Gaudin, 515 U.S. 506 (constitutional standard for burden of proof on factual issues)