Arizona Supreme Court

State of Arizona v. Dale Lee Evans

June 4, 2015237 Ariz. 231

Summary

The court held that reasonable suspicion for an investigatory vehicle stop does not require the state to show that the observed circumstances eliminate a substantial portion of innocent motorists. The totality of the circumstances, viewed through common sense and reasonable inferences, supported the deputy’s particularized suspicion that Evans might be assaulting his passenger, and the court therefore upheld the denial of suppression. The court also held that officers need not expressly rule out innocent explanations or provide separate testimony addressing the effect on innocent travelers.