The Colorado Supreme Court issued its opinion in People v. Crum on Tuesday, November 12, 2013.
Vehicular Search Incident to Arrest—Reasonable Articulable Suspicion—Reasonable Searches and Seizures—Suppression of Evidence.
The Supreme Court held that where a defendant is seen retrieving controlled substances packaged in a manner consistent with the intent to distribute from a vehicle parked late at night in an area known for high volumes of drug activity, and where the defendant attempts to conceal the substances, the facts and circumstances give rise to a reasonable articulable suspicion that the vehicle might contain more evidence of possession of a controlled substance. Under such circumstances, police officers may search the vehicle incident to the defendant’s arrest for possession of a controlled substance. The Court therefore reversed the order of the trial court suppressing evidence discovered during the search.
Summary and full case available here.