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Supreme Court Vacates Conviction Because Evidence was Discovered During an Unconstitutional Detention

In State v. Alexander, 2016 VT 19 (February 12, 2016), the Vermont Supreme Court reversed a ruling on a motion to suppress evidence due to an illegal seizure, vacated the Defendant’s conviction, and remanded.

Issue: Defendant challenged the denial of his motion to suppress evidence, arguing that it was obtained as a result of an unlawful seizure.

Holding: After reviewing the law regarding traffic stops and search and seizures, the Court held the Defendant had been detained beyond the time necessary to effectuate the purpose of the legitimate traffic stop, and thus the police were required to have additional reasonable suspicion to support the extended seizure. The Court held that the police did not have sufficient reasonable suspicion of criminal wrongdoing, and so it held the extended seizure was unconstitutional. Since the stop was an illegal detention, the Defendant’s consent to search his possessions during that detention was invalid, and the evidence found should have been suppressed. Accordingly, the Court vacated the conviction and remanded the case.

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