When reviewing the denial of a motion to suppress evidence, what is the test for determining whether a search or seizure under the Fourth Amendment was reasonable?

California, United States of America


The following excerpt is from People v. Williams, B246512 (Cal. App. 2014):

When reviewing the denial of a motion to suppress evidence, "[w]e defer to the trial court' s factual findings, express or implied, where supported by substantial evidence. In determining whether, on the facts so found, the search or seizure was reasonable under the Fourth Amendment, we exercise our independent judgment. [Citations.]" (People v. Glaser (1995) 11 Cal.4th 354, 362.)

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A police officer may conduct a traffic stop if he or she has a reasonable suspicion that the detainee is engaged in criminal activity. The suspicion must be based on specific, articulable facts that give rise to inferences that are objectively and reasonably drawn. An officer can "rely on his training and experience in drawing inferences from the facts he observes, but those inferences must . . . 'be grounded in objective facts and be capable of rational explanation.' [Citations.]" (U.S. v. Lopez-Soto (9th Cir. 2000) 205 F.3d 1101, 1105; People v. Souza (1994) 9 Cal.4th 224, 231 [a police officer must "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"].)

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