Supreme Court of Colorado

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

May 10, 2010229 P.3d 1054

Summary

The court affirmed suppression of drugs and paraphernalia found in the defendant's vehicle after her arrest for false reporting. Because she was handcuffed and secured in a patrol car when officers searched the vehicle, and because the officers already possessed the documents relevant to the false-reporting arrest, the search was not justified under the vehicle-search exception for searches incident to arrest. Justice Eid, dissenting, would have applied the good-faith exception based on preexisting precedent.