AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant, Tiffany Brown, was convicted of possession of a controlled substance, fourth degree, following a conditional plea. The conviction stemmed from an incident where Officer Prince conducted a patdown search of the Defendant, who was identified as a person with prior police contact and listed as dangerous. During the interaction, the Defendant appeared intoxicated, acted strangely, and did not comply with the officer's requests not to put her hands in her pockets, instead wrapping herself in a blanket (paras 2, 9).

Procedural History

• Appeal from the District Court of San Juan County, John A. Dean Jr., District Judge, May 11, 2016: The Defendant's conviction was affirmed.

Parties' Submissions

• Defendant-Appellant: Argued that the officer lacked reasonable suspicion to conduct the patdown search and to detain the Defendant. Additionally, the Defendant contended that she was denied a fair suppression hearing due to the State withholding the officer's lapel video until after the hearing (paras 2, 9, 12).
• Plaintiff-Appellee: Maintained that the officer had sufficient reasonable suspicion for both the patdown search and the detention of the Defendant based on her behavior, appearance, and prior police contact. The State also argued against the viability of the Defendant's request to amend the docketing statement to include an issue regarding the suppression hearing (paras 2, 9, 12).

Legal Issues

• Whether the officer had reasonable suspicion to conduct a patdown search of the Defendant (para 2).
• Whether the officer had reasonable suspicion to detain the Defendant (para 9).
• Whether the Defendant was denied a fair suppression hearing due to the withholding of the officer's lapel video (para 12).

Disposition

• The Court of Appeals affirmed the Defendant's conviction (para 14).

Reasons

• The Court, per Judge Jonathan B. Sutin, with Judges James J. Wechsler and M. Monica Zamora concurring, held that:
  The officer had a sufficient degree of articulable suspicion that the Defendant was both armed and presently dangerous to justify the frisk, based on the Defendant's prior police contact, behavior, and failure to comply with the officer's requests (para 2).
  The officer had reasonable suspicion to detain the Defendant for trespass based on the dispatch regarding an "unwanted person" and the Defendant's behavior and appearance upon the officer's arrival (para 9).
  The Defendant's request to amend the docketing statement to include an issue regarding the suppression hearing was denied as non-viable. The Court concluded that even assuming the State's failure to provide the lapel video constituted error, the Defendant failed to demonstrate how the video would have changed the outcome of the proceeding, thus not rising to the level of fundamental error (para 12).