State of Utah, Plaintiff and Respondent v. Jose Francisco Arroyo, Defendant and Petitioner

Summary

The Utah Supreme Court reversed the Court of Appeals and remanded the case for an evidentiary hearing on the voluntariness, exploitation, and scope of the consent search. It held that the traffic stop was an unconstitutional pretext and that the trial court’s finding of consent was clearly erroneous. The Court also rejected the Carson test, requiring a two‑part analysis of consent after police misconduct.