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