State v. Bonillas

OPINION

HOWARD, Judge.

¶ 1 The state appeals from the trial court’s order granting appellee Jaime Damian Bonil-las’s motion to suppress cocaine that an officer found when he conducted a pat-down search of Bonillas for identification before arresting him for violating A.R.S. § 28-1595(B), failure to provide an operator’s license or evidence of identity. The court found that there was no probable cause to arrest Bonillas and that, even if there was probable cause, the search was impermissible because it occurred before the arrest. Because we conclude that the officer had probable cause to arrest…