People v. Sykap

Superior Court of Guam·Decided November 27, 2013·No. CM0522-11·Unknown

Opinion

IN THE SUPERIOR COURT OF GUAM

2 THE PEOPLE OF GUAM, )

3 CRIMINAL CASE NO. CM0522-ll )

4 vs. )

) DECISION AND ORDER 5 JUNIOR J. SYKAP, )

)

6 Defendant. )

7

8 INTRODUCTION

9 This matter came before the Honorable James L. Canto II on Defendant's motion to 10 suppress, filed March 12, 2012. Oral arguments were heard on September 9, 2013. Assistant 11 Attorney General James L.G. Stake appeared on behalf of the Government and Assistant Public 12 Defender Suresh Sampath represented the Defendant. Having considered the parties' briefs, 13 oral arguments, and the applicable law, the Court now issues the following Decision and Order.

14 BACKGROUND

15 Defendant is charged with driving while under the influence of alcohol based upon the 16 following alleged events. On April 26, 2011 at approximately 1:49 a.m., Guam Police Officer 17 James N. Muna observed Defendant's vehicle with rear-end damage, pulled over the car, and 18 met with Defendant. (Testimony of James N. Muna, Record Log at 2:58, September 9, 2013).

19 Officer Muna inquired whether Defendant was involved in an auto-accident. Defendant 20 answered that he had not been in an auto-accident. !d. As the Defendant spoke, Officer Muna 21 noted a strong smell of alcohol from Defendant's breath. !d. Officer Muna requested that the 22 Defendant perform a field sobriety test, and Defendant refused to perform that test. !d. At 23 approximately 1:55 a.m., Officer Muna handcuffed the Defendant, placed Defendant in the 24 caged patrol vehicle, and subsequently transported Defendant to the Tumon/Tamuning precinct.

25 !d. Defendant was informed of his arrest at approximately 2:45 a.m. !d. Defendant was never 26 informed that he was under arrest before that time. !d.

27 Prior to being informed of his arrest, Defendant was informed that he was being taken to 28

Page I of7

the precinct for "further investigations" and "to take the breathalyzer." (Testimony of Junior J.

2 Sykap, Record Log at 3:06, September 9, 2013). Defendant was not informed of his Miranda 3 rights when he was placed in Officer Muna's patrol vehicle. !d. Defendant felt that he had no 4 choice but to follow Officer Muna's directions. !d. 5 It is undisputed that Defendant signed an implied consent form and completed a

6 breathalyzer test before being informed of his arrest at 2:45a.m. 7 On March 12, 2012, Defendant moved to suppress all the evidence obtained from the 8 investigative detention, the refusal to take the Standardized Field Sobriety Test, and the results 9 of the breathalyzer test because he asserts: 1) Defendant's detention lasted longer than fifteen 10 (15) minutes in violation of 8 GCA § 30.30; 2) no reasonable suspicion existed to stop 11 Defendant; and 3) the administration of the breathalyzer test before the formal arrest was a 12 violation of 16 GCA §1820l(b). The Government contends that Defendant was legally arrested l3 within 15 minutes of the time Officer Muna stopped Defendant, and therefore the 15 minute 14 rule of 8 GCA § 30.30 does not apply in this case. The Government further asserts that there 15 was reasonable suspicion to stop Defendant under the circumstances.

16

17 DISCUSSION

18 1. The 15-Minute Time Limit of the Stop and Frisk Act 19 The Fourth Amendment permits brief investigative detentions that are based upon a 20 reasonable suspicion of illegal conduct. People v. Johnson, 1997 Guam 9 ~ 4 (citing Terry v. 21 Ohio, 392 U.S. 1, 88 S.Ct. 1868 (1968)). This principle is codified in the entitled Stop and Frisk 22 Act at 8 GCA Chapter 30. See People v. Cundiff, 2006 Guam 12 ~ 40.

23

24 Title 8 GCA § 30.10 states:

Whenever a peace officer encounters any person under circumstances which 25 reasonably indicate that such person has committed, is committing or is about to 26 commit a criminal offense, the peace officer may detain such person.

27 \\\

Title 8 GCA § 30.20 states:

Detention pursuant to § 30.10 shall be for the purpose of ascertaining the identity of 2 the person detained and the circumstances surrounding his presence abroad which 3 lead the officer to believe that he had committed, was committing, or was about to commit a criminal offense, but such person shall not be compelled to answer any 4 inquiry of the peace officer. 5 Title 8 GCA § 30.30 states:

6 No person shall be detained under the provisions of§ 30.10 longer than is reasonably 7 necessary to effect the purposes of that section, and in no event longer than fifteen (15) minutes. Such detention shall not extend beyond the place where it was first 8 effected or the immediate vicinity thereof. 9 Title 8 GCA § 30.40 states:

10 If at any time after the onset of the detention authorized by § 30.1 0, probable cause II for arrest of the person shall appear, the person shall be arrested. If after an inquiry into the circumstances which prompted the detention, no probable cause for the 12 arrest of the person shall appear, he shall be released. 13

14 Thus under Guam law, a police officer having a reasonable suspicion regarding criminal 15 activity by a particular individual may detain that person to investigate said suspected criminal 16 activity. 8 GCA §§ 30.10 & 30.20 (2005). When this investigative detention reveals probable 17 cause for arrest, "the person shall be arrested." 8 GCA § 30.40 (2005). However, "in no event 18 [shall a person be detained] longer than fifteen (15) minutes," and the person "shall be

19 released," if no probable cause for arrest appears. 8 GCA §§ 30.30 & 30.40 (2005). 20 Despite the plain language of the statute, the Guam Supreme Court has found that 21 voluntary consent tolls the lapse of time accrued for purposes of the 15-minute rule. People v.

22 Taman, 2013 Guam 22 ~ 15. Furthermore, the Guam Supreme Court held that "the

23 development of probable cause obviates the fifteen-minute limit imposed by Guam's Stop and 24 Frisk Act on investigative detentions that are supported by reasonable suspicion, because the 25 appearance of probable cause transforms the nature of the detention and thereby removes the 26 encounter from the strict parameters of the statute." !d. at~ 27. Therefore, when a person is 27 detained without arrest for more than 15 minutes, without voluntary consent by the detainee or

the appearance of probable cause to arrest the detainee, the Stop and Frisk statutes are violated.

Free access — add to your briefcase to read the full text and ask questions with AI

People v. Sykap, (superctguam 2013).

People v. Sykap (People v. Sykap) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Beck v. Ohio
379 U.S. 89 (Supreme Court, 1964)
Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
Sibron v. New York
392 U.S. 40 (Supreme Court, 1968)
United States v. Marion
404 U.S. 307 (Supreme Court, 1971)
Dunaway v. New York
442 U.S. 200 (Supreme Court, 1979)
United States v. Mendenhall
446 U.S. 544 (Supreme Court, 1980)
People v. Maddox
294 P.2d 6 (California Supreme Court, 1956)