State v. Lambert

Defendant has petitioned for reconsideration of our decision in State v. Lambert, 263 Or App 683, 328 P3d 824 (2014). We held that the trial court erroneously denied defendant’s motion to suppress “all evidence discovered pursuant to the warrantless and unlawful ‘seizure’ of his vehicle.” Id. at 689. The trial court relied on the “administrative seizure” exception to the warrant requirement, but we concluded that the state had failed to demonstrate the applicability of that exception. Rather than reverse defendant’s convictions outright, however, we concluded that the proper disposition of…