v. Ashford, 2020 CO 16

A tip reported Ashford had argued with his girlfriend and might be a threat; tipster also said Ashford regularly sold methamphetamine.
An officer located Ashford, asked him and his girlfriend to stop, and patted Ashford down for weapons based on safety concerns.
During the frisk the officer felt what he believed was a pill bottle in Ashford’s pocket and asked: “I know this is a pill bottle, what is it?”
Ashford removed the pill bottle; the officer observed baggies of methamphetamine, arrested Ashford, and later found cash and unused baggies.
The district court suppressed all evidence, concluding the officer’s question exceeded the scope of the investigatory stop because the bottle was not a weapon; the People appealed to the Colorado Supreme Court.
The Colorado Supreme Court reversed, holding the single question did not measurably extend the stop and thus did not exceed the scope of the investigatory stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer’s question about the pill bottle exceeded the permissible scope of the investigatory stop (i.e., whether it "measurably extended" the stop)	The People: the single, off-topic question was minimally intrusive, took only seconds, did not measurably delay the stop, and fell within permissible inquiry during a Terry stop.	Ashford: the officer knew the object was not a weapon, so asking about it exceeded the purpose of the frisk and unlawfully expanded the detention.	Court: question did not measurably extend the stop; it was minimally intrusive and within the stop’s scope; suppression reversed.
Validity of the initial stop and protective frisk	The People: reasonable suspicion supported investigation of domestic violence; officer safety justified a weapons frisk.	Ashford: sought review of reasonable-suspicion basis.	Court: district court’s findings that reasonable suspicion and the protective pat-down existed were accepted; Supreme Court limited review to scope-of-stop issue.

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigatory stop and limited weapons frisk on reasonable suspicion)
Muehler v. Mena, 544 U.S. 93 (2005) (officers may pursue secondary inquiries that do not prolong a detention)
Arizona v. Johnson, 555 U.S. 323 (2009) (off-topic questioning allowed if it does not measurably extend the stop)
People v. Ball, 407 P.3d 580 (Colo. 2017) (single, minimally intrusive drug-related questions did not measurably extend a stop)
People v. Reyes-Valenzuela, 392 P.3d 520 (Colo. 2017) (framework: reasonable suspicion, reasonable purpose, and scope reasonably related to purpose)
People v. Chavez-Barragan, 379 P.3d 330 (Colo. 2016) (off-topic questioning permissible so long as it does not measurably extend the detention)
People v. Ingram, 984 P.2d 597 (Colo. 1999) (reasonable-suspicion standard for investigatory stops)