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Court Of Appeal Overturns Circuit Court Order. Subjective Motivation Of Officer Usually Not Relevan

By Expert Author: Joesph Affronti

In the matter of State vs. Proctor, the court of appeal reversed the circuit court's ruling allowing the defendant's motion to suppress evidence confiscated during the course of a traffic stop. The appellate court ruled that the circuit court committed reversable error by requiring the state to establish the stop was pretextual. The appellate court ruled that, as a rule-of-thumb, the choice to stop a vehicle is reasonable when the police have probable cause to believe that a traffic infraction has occurred. The appellate court additional ruled that the officer's motivation is irrelevant and shouldn't be considered as a factor in a run of the mill, probable-cause 4th Amendment analysis. Accordingly, the court held that the police officer did have probable cause sufficient to detain the defendant's car.

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