Summary
The Connecticut Supreme Court considered whether police had reasonable and articulable suspicion to conduct an investigative stop of the defendant’s vehicle. The court held that the totality of the circumstances—including the late hour, the high-crime area, the woman’s suspected prostitution, and her conduct in flagging down and entering the defendant’s vehicle—justified the stop. It reversed the Appellate Court and directed it to affirm the trial court’s denial of the motion to suppress.
Topics
Practice areas
Questions Presented
- Whether the police had reasonable and articulable suspicion to conduct an investigative stop of Lipscomb's motor vehicle.
- Whether the discovery of Lipscomb's suspended license resulted from an unlawful search or seizure and therefore should have been suppressed.
Holdings
- The investigative stop was constitutionally justified because, under the totality of the circumstances, the officers had a particularized and objective basis to suspect that Lipscomb was soliciting a prostitute.
- Because the initial stop was lawful, the officers' routine check of Lipscomb's license and registration was permissible, and the evidence that his license was suspended was not obtained through an illegal search or seizure.
Key quotations
“Reasonable and articulable suspicion is an objective standard that focuses not on the actual state of mind of the police officer, but on whether a reasonable person, having the information available to and known by the police, would have had that level of suspicion.” (75)
“In determining whether a detention is justified in a given case, a court must consider if, relying on the whole picture, the detaining officers had a particularized and objective basis for suspecting the particular person stopped of criminal activity.” (76)
Factual background
Late at night in a high-crime area of East Hartford, police officers observed Lipscomb's vehicle approach a woman who was waving her arm from a street corner, pick her up, and drive to a dead-end public street. One officer knew the woman had previously been involved in prostitution at a local hotel, and the officers believed the circumstances suggested solicitation of prostitution. They stopped the vehicle, conducted a routine motor-vehicle check, and discovered that Lipscomb's operator's license was suspended.
Procedural history
Lipscomb was charged with operating a motor vehicle with a suspended license under General Statutes § 14-215(c). The trial court denied his motion to suppress, concluding that the stop was supported by reasonable and articulable suspicion, and entered judgment after his conditional nolo contendere plea. The Appellate Court reversed, but the Supreme Court of Connecticut reversed the Appellate Court and remanded with direction to affirm the trial court's judgment.
Remand instructions
Reverse the judgment of the Appellate Court and remand the case to that court with direction to affirm the judgment of the trial court.