The People of the State of Colorado, Plaintiff-Appellant: v. Marcelino Andrade Moreno. Defendant-Appellee:, 2022 CO 19

In Jan. 2021 an anonymous tip to the Northern Colorado Drug Task Force identified a Berthoud house and gave detailed allegations (names, phone numbers, physical descriptions, vehicle description—a white GMC Acadia—types of drugs, storage location, and how sales occurred).
The task force delayed three months, then surveilled the residence and confirmed the occupants, the described woman, and the described GMC Acadia.
Marcelino Moreno arrived in a pickup, greeted the male resident, went into a shed with him and emerged empty‑handed; officers observed Moreno behaving hypervigilantly (looking over his shoulder, watching a patrol car).
Officers followed Moreno to a truck stop where he parked without fueling, lingered by an air‑compressor holding the hose but did not use it, and continuously watched the patrol car; he later reunited with the residents and entered their SUV carrying a black backpack.
Officers stopped the SUV, a K9 alerted, and the backpack searched contained ~460 g suspected methamphetamine and 13.3 g suspected fentanyl.
The trial court suppressed the evidence, finding the three‑month‑old anonymous tip stale and the officers’ observations an insufficient articulable suspicion; the People appealed interlocutorily to the Colorado Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, articulable suspicion to stop the vehicle	Totality (detailed tip corroborated + Moreno’s suspicious, hypervigilant conduct + reunion with residents carrying a backpack) gave rise to reasonable suspicion	The anonymous tip was stale after three months and officers’ observations were only a hunch or could be innocent conduct	Reversed: under the totality of circumstances officers had reasonable suspicion to conduct the stop
Whether the age of the anonymous tip (staleness) defeated its corroborative value	The tip’s detailed specificity and factual corroboration by surveillance preserved its value despite age	Three‑month delay rendered the tip stale and insufficient to support suspicion	Staleness was a factor but not dispositive; corroboration + contemporaneous suspicious conduct overcame the delay

People v. Brown, 461 P.3d 1 (2019 CO 63) (articulable reasonable‑suspicion standard; consider totality of circumstances)
Terry v. Ohio, 392 U.S. 1 (1968) (permitting brief investigatory stops based on reasonable suspicion)
Navarette v. California, 572 U.S. 393 (2014) (anonymous tip reliability in the reasonable‑suspicion context)
People v. Revoal, 269 P.3d 1238 (2012 CO 8) (holding that isolated suspicious behavior without corroboration may be insufficient for reasonable suspicion)
People v. Wheeler, 465 P.3d 47 (2020 CO 65) (courts look for specific, articulable facts known to the officer; reasonable inferences from circumstantial evidence)
People v. McIntyre, 325 P.3d 583 (2014 CO 39) (standard of review for suppression orders: defer to factual findings, legal conclusions reviewed de novo)