People v. Brown.

2022 CO 11. No. 21SA110. Criminal Law—Searches and Seizures—Probable or Reasonable Cause.

March 8, 2022

The People brought this interlocutory appeal under C.A.R. 4.1, challenging the district court’s order suppressing defendant’s statements following his detention by the police. The trial court determined that the officers who detained defendant did not have a reasonable and articulable suspicion that a crime had been committed, was being committed, or was about to be committed.

The Supreme concluded that while the trial court erred in considering the officers’ subjective intent in effectuating the seizure, it was nonetheless correct that the officers lacked reasonable and articulable suspicion to detain defendant. Accordingly, the trial court’s order suppressing Brown’s statements was affirmed, albeit on other grounds.