State v. Sanchez-Granado, 2017 UT App 98

On May 18, 2016 detectives Lovendahl and Lloyd surveilled a white Lexus in a Salt Lake County Wal‑Mart parking lot for ~20 minutes; occupants sat in the car, used phones, and did not enter the store.
The Lexus drove to another part of the lot where it met a Chevy Tahoe and a motorcycle; passengers from those vehicles entered the Lexus’ back seat.
Detectives approached to investigate; Lloyd activated lights and, while approaching, observed a rear passenger holding a folding knife and cash and saw a baggie of colorful small balloons in the center console (consistent with drug packaging).
Based on those observations the detectives developed probable cause, searched the vehicle, and seized a knife and heroin and cocaine.
Sanchez‑Granado moved to suppress evidence, arguing the initial detention was an unsupported level‑two stop because the observed conduct had innocent explanations and the court relied on officers’ subjective views.
The district court denied the motion; Sanchez‑Granado preserved appellate review via a conditional guilty plea and appealed the denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether detectives had reasonable articulable suspicion to detain (level‑two stop)	Surveillance conduct (sitting, using phones, looking around, short meeting) was innocuous and not sufficient for reasonable suspicion; court relied on officers’ subjective impressions	Totality of circumstances + officers’ experience supported reasonable suspicion to investigate drug trafficking	Court affirmed: reasonable articulable suspicion existed based on totality and officers’ training/experience
Whether district court improperly relied on subjective officer views	Officers’ subjective beliefs cannot substitute for objective reasonable suspicion and innocent explanations were not adequately considered	Courts may consider officers’ training/experience and give deference to their ability to distinguish suspicious conduct; not required to rule out innocent explanations	Court held reliance on officers’ experience and reasonable inferences was proper; court examined totality and considered innocent explanations but found them insufficient

State v. Fuller, 332 P.3d 937 (Utah 2014) (standard of review for suppression motions: mixed question of law and fact)
State v. Gurule, 321 P.3d 1039 (Utah 2013) (review as a matter of law whether facts give rise to reasonable suspicion)
State v. Markland, 112 P.3d 507 (Utah 2005) (officers need not eliminate innocent explanations; deference to officer judgment)
State v. Warren, 78 P.3d 590 (Utah 2003) (courts must view articulable facts in totality and avoid evaluating facts in isolation)
United States v. Williams, 271 F.3d 1262 (10th Cir. 2001) (courts should judge officer conduct with common sense and defer to trained officers’ assessments)
State v. Anderson, 316 P.3d 949 (Utah Ct. App. 2013) (totality of circumstances test for reasonable articulable suspicion)