Suppression of Evidence-

WI Court of Supreme Court

Case Name: State of Wisconsin v. Quaheem O. Moore

Case No.: 2021AP000938-CR

Officials: Brian Hagedorn, J.

Focus: Suppression of Evidence-

The Supreme Court reversed the court of appeals’ decision that upheld the circuit court’s ruling to suppress the search results in a case. The court held that the law enforcement officers had sufficient probable cause to arrest the defendant, making the subsequent search a lawful search incident to arrest.

The case began with a traffic stop conducted by a police officer due to the defendant’s speeding. During the initial interaction, the officer detected the smell of raw marijuana emanating from the defendant’s vehicle. Additional officers were called for support, and the defendant was asked to step out of the vehicle. Based on the odor of marijuana, the officers conducted a search and discovered two baggies containing cocaine and fentanyl. The defendant filed a motion to suppress, arguing that the State lacked probable cause for the arrest and search. The circuit court granted the motion, and the court of appeals affirmed this decision. However, the Supreme Court reversed both lower courts, determining that, considering all the circumstances, the officers had sufficient probable cause to arrest the defendant based on the belief that he had committed or was committing a crime. As a result, there was no violation of the Fourth Amendment.

Reversed

Decided 06/20/23

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