People v. Celis

Opinion

KENNARD, J.

Suspecting defendant of drug trafficking, police officers stopped him at gunpoint behind his house, handcuffed him, and made him sit on the ground. The officers then entered defendant’s house to determine whether there was anyone inside who might endanger their safety. They did not find anyone, but they did see a large box with uniformly sized, wrapped packages that, after a search, proved to contain cocaine.

We address two issues. Was the officers’ initial seizure of defendant an arrest requiring probable cause, or was it merely a detention requiring only a reasonable…