What is the standard of review on appeal from the denial of a motion to suppress?

California, United States of America


The following excerpt is from In re Robert H., E044204 (Cal. App. 4/4/2008), E044204 (Cal. App. 2008):

"Our standard of review on appeal from the denial of a motion to suppress is well established. We defer to the trial court's factual findings where supported by substantial evidence, but we must exercise our independent judgment to determine whether, on the facts found, the search and seizure was reasonable under the Fourth Amendment standards of reasonableness. [Citation.]" (People v. Avila (1997) 58 Cal.App.4th 1069, 1073-1074; accord People v. Memro (1995) 11 Cal.4th 786, 846.) The standard of review of a trial court's ruling on a motion to suppress is equally applicable to juvenile court proceedings. (In re Lennies H. (2005) 126 Cal.App.4th 1232, 1236.)

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