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State v. Williams
270 Or. App. 721
Or. Ct. App.
2015
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Background

  • After a stipulated facts trial, defendant was convicted of felon in possession of a firearm and unlawful possession of cocaine.
  • Defendant moved to suppress evidence, arguing the search warrant lacked probable cause, which the trial court denied.
  • Detective Goodwin described a shooting scene with shell casings, bullet holes, and a bullet-damaged bus windshield, and identified a potential shooter and vehicle.
  • An eyewitness described a cream-colored Toyota and a group on the sidewalk; defendant allegedly drove Riley to the hospital, and Riley was a shooting victim.
  • Goodwin’s affidavit claimed training and experience linking firearms offenses to cars and evidence hidden in vehicles, seeking to search defendant’s Buick.
  • The court reversed, holding the affidavit did not establish probable cause to search the Buick.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Did the warrant affidavit establish probable cause to search the Buick? State argued sufficient linkage between car and shooting. Garrett contended facts were too attenuated to show probability. Probable cause not shown; warrant invalid.

Key Cases Cited

  • State v. Castilleja, 345 Or 255 (2008) (probable-cause standard for warrants; need more than suspicion)
  • State v. Tropeano, 238 Or App 16 (2010) (well-warranted suspicion is insufficient for probable cause)
  • State v. Castro, 194 Or App 109 (2004) (probability must show more likely than not)
Read the full case

Case Details

Case Name: State v. Williams
Court Name: Court of Appeals of Oregon
Date Published: May 6, 2015
Citation: 270 Or. App. 721
Docket Number: 130130151; A154948
Court Abbreviation: Or. Ct. App.