State v. Bruce

Roger Bruce was convicted of murdering his girlfriend Laura Creel. On appeal, he argues the trial court erred in admitting evidence of the discovery of Creel’s body, which police found in the trunk of her car, because he claims the search violated his Fourth Amendment rights. In ruling on the issue at trial, the court did not make adequate factual findings or legal conclusions. Rather, the court summarily stated, “I’m going to overrule the objection and allow it.” We hold the trial court’s findings are inadequate for appellate review. We remand to the trial court to determine (1) whether…