People v. Coates

The People brought an interlocutory appeal pursuant to section 16-12-102(2), C.R.S. (2011), and C.A.R. 4.1, challenging the district court's suppression of evidence seized from the trunk of the defendant's vehicle. Upon discovering a bindle and single pre-seription pill in the driver's pants pocket, the police arrested him, placed him in their patrol car, and searched the vehicle. The district court found that the police lacked any reasonable and articulable basis to search the defendant's trunk incident to the arrest of the driver, and that they therefore also lacked probable cause for a…