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Name: People v. Flores (2024) 15 Cal.5th 1032
Case #: S267522
Court: CA Supreme Court
District CalSup
Opinion Date: 05/02/2024
Summary

Under the Fourth Amendment, detention was unauthorized where defendant’s odd behavior, while noteworthy, did not support a reasonable suspicion that he was engaged in illegal activity. Officers observed defendant, alone, in a known narcotics area around 10:00 p.m. Defendant ducked behind a vehicle and pretended to tie his shoe. Officers approached and detained defendant, subsequently locating drug paraphernalia and a revolver in his nearby vehicle. The Supreme Court concluded that the trial court erred in denying defendant’s motion to suppress evidence recovered during the detention. Defendant’s behavior, while odd, did not provide a reasonable suspicion of criminal activity. Defendant was not interacting with any other individuals in a known narcotics area, he did not participate in a “headlong flight,” and there was no call for help or report of a crime in progress. Because the detention was unjustified under the totality of the circumstances, defendant’s suppression motion should have been granted. [Editor’s Note: The concurring opinion noted that for many people, particularly people of color, attempting to avoid police officers is simply a desire to avoid risking injury or death.]

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/S267522.PDF