People v. Liang

CourtSuperior Court of Guam
DecidedNovember 26, 2012
DocketCM0984-11
StatusUnknown

This text of People v. Liang (People v. Liang) is published on Counsel Stack Legal Research, covering Superior Court of Guam primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Liang, (superctguam 2012).

Opinion

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2 THE PEOPLE OF GUAM, ) 3 ) vs. ) CLEF::< OF COURT 4 ) BY ) 5 HU SHAN LIANG, ) DECISION AND ORDER 6 ) Defendant. ) 7 ) 8

9 This matter came before the HONORABLE VERNON P. PEREZ on October 31,2012 10 for Defendant's Motion to Suppress. Assistant Public Defender Suresh Sampath represented 11 Defendant, who was present. Assistant Attorney General Frances C. DeCecco appeared on 12 behalf of the Government. The Court took the motion under advisement. After hearing the 13 Parties' arguments, reviewing the record and considering the Parties' pleadings, the Court now 14 issues the following Decision and Order. 15 BACKGROUND 16 On or about September 17, 2011, Defendant was charged with driving while under the 17 influence of alcohol, reckless driving and operating a motor vehicle without a valid license. 18 Preceding his arrest, Defendant was discovered at approximately 9:20p.m., on the roadway, 19 traveling into the opposite lane almost colliding with oncoming traffic. Defendant filed a Notice 20 of Motion and Motion to Suppress on September 13, 2012. On October 31, 2012, the Court 21 heard the matter. This Decision and Order will only address Defendant's Motion to Suppress. 22 DISCUSSION 23 Timeliness of Governments Opposition 24 Defendant argues that the Government's Opposition should be deemed untimely and not 25 considered. The Court finds that the Government responded to Defendant's Motion within 12 26 days on September 25, 2012. Furthermore, the Government only had a few days to file an 27 opposition within the guidelines and the Court finds a good cause argument to the untimely 28

People v. Liang, Decision and Order Criminal Case No. CM0984-11 - Page I of5- filing. Finally, the Court would have evaluated the merits of Defendant's Motion to Dismiss in 2 the event no opposition was filed. 3 Defendant Consented to Any Detention Over 15 Minutes 4 Defendant moves to suppress any and all evidence obtained by police officers as a result 5 of an unlawful detention of his person in violation of 8 Guam Code Annotated §§ 30.10-30.60, 6 Guam's Stop and Frisk statute. Guam law provides, "[n]o person shall be detained under the 7 provisions of § 30.10 longer than is reasonably necessary to effect the purposes of that section, 8 and in no event longer than 15 minutes ... " 8 GCA § 30.30. Defendant argues that he was 9 detained for more than the permitted 15 minutes, therefore, the remedy for a Stop and Frisk 10 violation should be suppression of all evidence seized. 11 The purpose for Guam's Stop and Frisk Act is to set guidelines for investigatory stops 12 where the police officer has reasonable suspicion that a person has or is about to commit a 13 criminal offense. 8 G.C.A. § 30.1 O. A police officer then has 15 minutes to ascertain the 14 identity of the person detained and to determine the circumstances surrounding his presence 15 which lead the officer to believe that he committed, was committing or was about to commit a 16 criminal offense. 8 G.C.A. § 30.20. If probable cause arises any time after the onset of the 17 detention, the person shall be arrested. 8 G.C.A. § 30.40. The time limitation under Section 18 30.10 is no longer applicable once probable cause has been formed or a defendant is arrested. 19 During the investigatory stop, here, Officers had probable cause to arrest Defendant 20 based on the plentiful evidence to suggest a criminal violation. Very early into the police 21 interactions with Defendant, well before 15 minutes elapsed, Defendant admitted to driving 22 without a valid license and appeared to have several indicators of intoxication. Once probable 23 cause is formed during the investigatory stop, the 15 minute time limit for the purposes of 24 Section 30.10 no longer governs. The investigatory stop then becomes a detention and need 25 only pass a constitutional analysis against unreasonable searches and seizures guaranteed by the 26 Fourth Amendment. 27 The United States Supreme Court has repeatedly rejected the application of a bright-line 28 time limit for Fourth Amendment detentions. See United States v. Sharpe, 470 U.S. 675, 685

People v. Liang, Decision and Order Criminal Case No. CM0984-11 - Page 2 of5- (1985). Although having a 'bright-line' rule would be helpful in evaluating whether an 2 investigative detention is unreasonable, a police officer's common sense and judgment must 3 ultimately govern their conduct. In United States v. Place, the court reasoned, "[s]uch a limit 4 would undermine the equally important need to allow authorities to graduate their responses to 5 the demands of any particular situation." Place, 462 U.S. 696, 709 (1983). The Guam 6 legislature has provided a clear framework for stops for the purposes of Sections 30.30-40, 7 which at any time probable cause appears, the person shall be arrested. The 15 minute 8 limitation was inapplicable in this case since officers had probable cause to arrest. 9 More importantly, Defendant consented to the detention extending past 15 minutes by 10 agreeing to do field sobriety tests. The United States Supreme Court touched on the subject of 11 consent when stating "[w]e recognize, of course, that the choice to submit or refuse to take a 12 blood-alcohol test will not be an easy or pleasant one for a suspect to make. But the criminal 13 process often requires suspects and defendants to make difficult choices." South Dakota v. 14 Neville, 459 U.S. 553, 564 (1983). That discussion of the obligation of suspects to refuse 15 further compliance with the police leads this Court to reasonably conclude that Defendant 16 agreed to any delay in the detention caused by the field sobriety tests. The Court understands 17 that it would be a gamble for any individual to refuse cooperation with the police. Yet, the 18 Court will not apply the 15 minute rule and suppression of evidence where the police appear to 19 have acted entirely appropriately.l The Court concludes that if Defendant refused the field 20 sobriety tests, the police would have been able to make an arrest based on his intoxicated 21 appearance and lack of valid license. Here, the police were not required to make that 22 determination until after the field sobriety test completed due to Defendant's consent. The 23 Court would note that the police actually ended the field sobriety tests early and before 24 25 I The Court would note that in some cases, like this one, where there preexisting and overwhelming evidence to support a valid

26 probable cause based arrest, the field sobriety test is an opportunity for a suspect to show a lack of inebriation. Once substantial indicia of intoxication are present, or no valid driver's license, the police may already arrest a suspect. The Court views that it is possible that any further opportunity to show a lack of inebriation is an opportunity given to suspects to prove or plead innocence 27 In these situations, a person is obligated to refuse consent and gamble that there is not enough evidence to make an arrest and the police must decide on whether they release or arrest under the 15 minute rule. In Defendant's case, his driving ability, 28 appearance and lack of a valid driver's license was adequate such that any refusal to comply with the police request would have likely lead to an arrest.

People v. Liang, Decision and Order Criminal Case No. CM0984-11 - Page 3 of5- completion due to Defendant's inability to perform the tests and because Defendant presented 2 adequate indicia of DUI to make an arrest.

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Related

Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
South Dakota v. Neville
459 U.S. 553 (Supreme Court, 1983)
United States v. Place
462 U.S. 696 (Supreme Court, 1983)
Nix v. Williams
467 U.S. 431 (Supreme Court, 1984)
United States v. Sharpe
470 U.S. 675 (Supreme Court, 1985)
People v. Chambers
489 N.W.2d 168 (Michigan Court of Appeals, 1992)

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People v. Liang, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-liang-superctguam-2012.