State v. Bates

Summary

The court affirmed the denial of Bates's motion to suppress, holding that officers had reasonable suspicion to conduct an investigatory detention of the minivan. Although each circumstance could have an innocent explanation, the totality of the circumstances provided a particularized and objective basis to suspect that the occupants were about to engage in criminal activity. The court also held that appellate review of suppression rulings is bifurcated, with factual findings reviewed for substantial competent evidence and the reasonable-suspicion determination reviewed de novo.