v. Pettigrew

2020 COA 46
CourtColorado Court of Appeals
DecidedMarch 31, 2020
Docket16CA1319, People
StatusPublished
Cited by2 cases

This text of 2020 COA 46 (v. Pettigrew) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
v. Pettigrew, 2020 COA 46 (Colo. Ct. App. 2020).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY March 26, 2020

2020COA46

No. 16CA1319, People v. Pettigrew — Constitutional Law — Fourth Amendment — Searches and Seizures — Exclusionary Rule — Independent Source Exception

A division of the court of appeals considers what identifying

information must be included in a search warrant authorizing the

search of a cell phone to meet the Fourth Amendment’s

particularity requirement. The division concludes that the search

warrant in this case — identifying one phone that was registered to

a known phone number and that belonged to a known person —

was sufficiently particular under the Fourth Amendment. COLORADO COURT OF APPEALS 2020COA46

Court of Appeals No. 16CA1319 Adams County District Court No. 14CR234 Honorable Francis C. Wasserman, Judge Honorable Donald S. Quick, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

William Scott Pettigrew,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division VII Opinion by JUDGE BERGER Fox and Lipinsky, JJ., concur

Announced March 26, 2020

Philip J. Weiser, Attorney General, Megan C. Rasband, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Casey J. Mulligan, Alternate Defense Counsel, Boulder, Colorado, for Defendant-Appellant ¶1 William Scott Pettigrew appeals his convictions for pandering

of a child and tampering with a witness or victim. He contends that

two errors require reversal of his convictions. First, he claims that

the trial court’s statements made to the jury during voir dire

regarding reasonable doubt lowered the prosecution’s burden of

proof. Second, he asserts that evidence of the contents of his cell

phone was admitted in violation of the Fourth Amendment. This

second claim raises a question of first impression in Colorado:

What identifying information must be included in a search warrant

authorizing the search of a cell phone to meet the Fourth

Amendment’s particularity requirement?

¶2 We conclude that none the statements made by the trial court

lowered the prosecution’s burden of proof. We also conclude that

the independent source exception to the Fourth Amendment

exclusionary rule applied to the evidence found in Pettigrew’s phone

and that the search warrant sufficiently identified the phone to be

searched. Thus, we affirm the judgment.

I. Background

¶3 Pettigrew met the seventeen-year-old victim in 2013. After

interacting in person, over the phone, and by text, they began a

1 relationship. Text messages that Pettigrew sent to the victim

supported the prosecution’s theory that Pettigrew encouraged the

victim to become a prostitute. The victim’s mother contacted the

police after seeing sexually explicit photographs on the victim’s

phone.

¶4 After obtaining information from the victim, her cell phone,

and her mother, the police arrested Pettigrew inside his house

without a warrant.

¶5 The police interrogated Pettigrew after they transported him to

the police station.1 During the interrogation, Pettigrew showed the

police certain text messages on his cell phone. The police already

had possession of the phone; they had seized it after arresting

Pettigrew. Later that day, the police released Pettigrew because of

concerns by the arresting officers’ superiors that the arrest might

have been unlawful because it was effected without a warrant.

Although the police released Pettigrew, they kept his phone.

¶6 The next day, on the detective’s application, a magistrate

issued a warrant for Pettigrew’s arrest, and he was rearrested.

1Pettigrew does not raise any Fifth Amendment challenges on appeal.

2 Approximately a week later, the magistrate issued a search warrant

for the cell phone, which, as noted, had remained in police custody.

¶7 Pettigrew was charged with soliciting for child prostitution,

pandering of a child, sexual exploitation of a child, attempted

inducement of child prostitution, and tampering with a witness or

victim.

¶8 Pettigrew moved to suppress all of the information obtained

from his cell phone. He argued that the officers unlawfully arrested

him when they entered his home without a warrant and that the

seizure and later forensic examination of his cell phone were fruits

of the unlawful arrest. The trial court denied the motion,

concluding that exigent circumstances justified Pettigrew’s arrest.

¶9 The jury convicted Pettigrew of pandering of a child and

tampering with a witness or victim but acquitted him of the other

charges.

¶ 10 On appeal, in an unpublished remand order, a different

division of this court rejected the trial court’s conclusion that

exigent circumstances justified Pettigrew’s warrantless arrest.

People v. Pettigrew, (Colo. App. No. 16CA1319, Feb. 27, 2019)

(unpublished order). That division remanded to the trial court to

3 determine whether the independent source exception to the

exclusionary rule justified the admission of the evidence found on

the phone.2

¶ 11 The prior division identified two questions that governed

whether the independent source doctrine applied. First, was the

decision to seek the search warrant prompted by information

learned as a result of the unlawful arrest? Second, did any

information gained from the illegal search affect the magistrate’s

decision to issue the search warrant? The division answered the

second question in the negative. To do so, the division redacted

from the warrant affidavit all of the information that it believed was

discovered as a result of the unlawful arrest, and then concluded

that the warrant affidavit still established probable cause for the

issuance of the warrant. As to the first question, because issues of

2 Neither the prior division nor the trial court determined whether the police searched Pettigrew’s phone, within the meaning of the Fourth Amendment, when he showed the police certain text messages during custodial questioning. Even if a consensual search occurred, it remains true that the arrest was unlawful and the examination of the phone by the police, consensual or not, flowed directly from the unlawful arrest. Similarly, neither the prior division nor the trial court evaluated whether the seizure of the phone, as opposed to Pettigrew’s warrantless arrest, was justified by exigent circumstances. Because of our disposition, neither do we.

4 fact remained, the division remanded the case to the trial court to

determine if the information obtained from the search of the phone

before the warrant was issued affected the detective’s decision to

seek the search warrant.

¶ 12 On remand, the trial court (with a different judge presiding)

found that the detective’s decision to seek the search warrant was

not prompted or impacted by the evidence gathered as a result of

the illegal arrest. The court therefore concluded that the evidence

was admissible under the independent source exception. The

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2020 COA 46, Counsel Stack Legal Research, https://law.counselstack.com/opinion/v-pettigrew-coloctapp-2020.