What is the standard of review for a motion to suppress evidence in a juvenile court?

California, United States of America


The following excerpt is from People v. Vincent C. (In re Vincent C.), C084570 (Cal. App. 2019):

"The standard of review of a trial court's ruling on a motion to suppress is well-established and is equally applicable to juvenile court proceedings." (In re Lennies H. (2005) 126 Cal.App.4th 1232, 1236.) "In reviewing a trial court's ruling on a motion to suppress evidence, we defer to that court's factual findings, express or implied, if they are supported by substantial evidence. [Citation.] We exercise our independent judgment in determining whether, on the facts presented, the search or seizure was reasonable under the Fourth Amendment." (People v. Lenart (2004) 32 Cal.4th 1107, 1119.)

"A detention is reasonable under the Fourth Amendment when the detaining officer can point to specific articulable facts that, considered in light of the totality of the circumstances, provide some objective manifestation that the person detained may be involved in criminal activity." (People v. Souza (1994) 9 Cal.4th 224, 231.)

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