People v. Pham.

2025 CO 4. No. 24SA225. Fourth Amendment—Traffic Stop—Probable Cause—Drug-Detection Dog.

February 3, 2025

In this interlocutory appeal, the supreme court concluded that although the trial court erred in finding that removing Pham from his vehicle during a lawful traffic stop was a search, the court correctly determined that the dog’s entry into Pham’s vehicle, which was facilitated by the police, was a search under the Fourth Amendment and that this search was conducted without the requisite probable cause.

Accordingly, the court affirmed the trial court’s suppression order and remanded this case to the trial court for further proceedings consistent with this opinion.