The People of the State of Colorado, Plaintiff-Appellant v. Stephanie Spring Chamberlain, Defendant-Appellee

Summary

The court affirmed suppression of drugs and paraphernalia found during a search of the defendant’s vehicle after her arrest for false reporting. Because she was handcuffed and secured in a patrol car, the search could not rest on an officer-safety or access rationale, and the officers lacked a reasonable basis to believe the vehicle contained evidence of the arrest offense. The case was remanded for further proceedings. Justice EID, dissenting, would have applied the good-faith exception based on reliance on preexisting precedent.