Colorado v. Reyes-Valenzuela
Annotate this CaseAround 11:30 p.m., a concerned citizen (“the caller”) called law enforcement after witnessing a possible break-in in a partially developed residential neighborhood. The caller said he saw a person, later identified as Defendant Gonzalo Reyes-Valenzuela, enter several unfinished houses, leave one of the houses carrying a black bag, and use a light-colored, boxy van to travel between houses. The issue this interlocutory appeal presented for the Supreme Court’s review centered on whether an officer, with a reasonable, articulable suspicion that criminal behavior was afoot, had to consider the possible innocent explanations for otherwise suspicious behavior before conducting an investigatory stop. Specifically, when an officer is aware that a person is driving around late at night, going in and out of unfinished houses in an area where there had been recent break-ins of unfinished houses, and carrying a black bag, is that officer required to consider possible innocent explanations before conducting an investigatory stop of that person? The Supreme Court held that, because Colorado and United States Supreme Court precedent does not require an officer to consider every possible innocent explanation for criminal behavior, the officers in this case justifiably performed an investigatory stop on the defendant based on a reasonable, articulable suspicion of ongoing criminal activity. The Court therefore reversed the trial court’s suppression order and remanded for further proceedings.
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