State of Utah, Plaintiff and Respondent v. Angie Brake, Defendant and Petitioner

Summary

The Utah Supreme Court held that the officer's warrantless entry into and search of the vehicle for a purse was not justified by officer-safety concerns because the circumstances did not create a reasonable, articulable suspicion that weapons were present. The court also clarified that appellate courts must review the application of law to fact and the reasonableness of protective searches without deference in search-and-seizure cases. It reversed the court of appeals and remanded for proceedings consistent with the opinion and the conditional guilty plea.