Supreme Court of Rhode Island
State v. Jerome Joseph State v. Voguel Figaro
July 20, 2023
Summary
The Supreme Court of Rhode Island affirmed the Superior Court’s orders granting the defendants’ motions to suppress, holding that the police lacked reasonable suspicion to prolong the traffic stop and conduct a dog sniff, and that the hearing justice’s sua sponte discussion of racial bias did not affect the decision. The Court applied a de novo review of the reasonable‑suspicion analysis and found the stop unreasonably extended beyond its traffic‑enforcement purpose.