State v. Suppah, 334 P.3d 463

Defendant convicted of giving false information to a police officer after an unlawful traffic stop on I-84.
Officer Hulke stopped defendant for an unknown traffic violation; no documented reason or warning was provided.
Defendant gave a false name; a DMV check showed Pennington’s license was suspended, leading to citations in Pennington’s name.
About a month later, defendant admitted giving a false name; Shull obtained a written statement from defendant.
The motion to suppress all evidence from the stop argued the stop violated Article I, section 9, and that attenuation under Hall applied.
Trial court acknowledged the stop was illegal but held there was substantial attenuation; defendant was convicted of false information.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the unlawful stop tainted the challenged evidence under Article I, section 9.	State argues attenuation can cure taint if independent or tenuously linked.	Defendant contends all evidence from the stop should be suppressed as fruit of illegality.	Unattenuated taint; statements during the stop suppressed.
Whether the Hall framework governs whether evidence derived from an unlawful stop is admissible.	State relies on Hall to allow attenuation or independent source.	Defendant argues the evidence was tainted and must be excluded unless independent or tenuously linked.	Hall applies; the early statements were tainted and excluded.
Whether the later statements (one month after the stop) are admissible under Hall or other exceptions.	State contends intervening voluntary act attenuates link; Gaffney exception may apply for independent crime.	Defense argues attenuation and lack of exploitation negate taint; Gaffney not applicable here.	Later statements attenuated; not suppressed under Hall; however, overall admission still tainted by earlier stop leading to reversal leave to suppress the early statements.

Hall, 339 Or 7 (2005) (two ways unlawful stop can taint evidence; Wong Sun framework for attenuation)
Starr, 91 Or App 267 (1988) (identity obtained from unlawful stop; taint doctrine pre-Hall)
Farley, 308 Or 91 (1989) (consent/search taint when stop lacks authority)
Rodriguez, 317 Or 27 (1993) (but-for causation not alone bar to admissibility; factors for exploitation)
Toevs, 327 Or 525 (1998) (unlawfully extended stop and suppression principles)
Dominguez-Martinez, 321 Or 206 (1995) (extension of stop and suppression principles)
Rodgers/Kirkeby, 347 Or 610 (2010) (illegal extension of stop; suppression of evidence obtained during inquiry)
Williams, 161 Or App 111 (1999) (attenuation in a post-arrest context; limits of Gaffney-type reasoning)
Crandall, 340 Or 645 (2006) (attenuation after unlawful stop where intervening voluntary act reduces taint)