State of Utah, Plaintiff and Appellee v. Jose Carlos Pena, Defendant and Appellant

Summary

The Utah Supreme Court affirmed the trial court's denial of Jose Carlos Pena's motions to suppress, covering a dispatched-report stop, his Miranda waiver, his misdemeanor arrest for giving false personal information, and a jail strip search that produced cocaine. The court held that reasonable-suspicion determinations are legal conclusions reviewed nondeferentially for correctness, though the standard conveys a measure of discretion to trial judges, and it articulated a 'spectrum of discretion' framework for calibrating appellate scrutiny of law-to-fact applications. On the merits it found the stop justified by the broadcast description, the waiver valid under a totality-of-the-circumstances assessment, probable cause for the arrest (mooting the pretext claim), and the strip search justified under the federal reasonableness-balancing test given the officer's observation of concealment behavior.