Ratliff v. State, 49S02-0112-CR-656.
| Court | Supreme Court of Indiana |
| Citation | 770 N.E.2d 807 |
| Docket Number | No. 49S02-0112-CR-656.,49S02-0112-CR-656. |
| Parties | Jason RATLIFF, Appellant (Defendant below), v. STATE of Indiana, Appellee (Plaintiff below). |
| Decision Date | 28 June 2002 |
770 N.E.2d 807
Jason RATLIFF, Appellant (Defendant below),v.
STATE of Indiana, Appellee (Plaintiff below)
No. 49S02-0112-CR-656.
Supreme Court of Indiana.
June 28, 2002.
Steve Carter, Attorney General of Indiana, Grant H. Carlton, Deputy Attorney General, Indianapolis, IN, Attorneys for Appellee.
ON PETITION TO TRANSFER
SULLIVAN, Justice.
Defendant Jason Ratliff appeals the trial court's denial of his request that evidence discovered in a search of the truck he crashed while fleeing police not be used against him. Finding that the evidence was discovered in a lawful inventory of the truck's contents, we affirm the trial court's decision.
Background
In October, 1999, the Louisiana State Police stopped a vehicle in which they found approximately sixty-four thousand doses of valium. The occupants of the car, Roberto Hernandez and Claudia Ortega, indicated that they intended to deliver the valium to Defendant in Indianapolis, Indiana. Detectives in Indianapolis secured a room in a motel to conduct a controlled buy from Defendant. Hernandez contacted Defendant who agreed to conduct the transaction at the motel. When Defendant arrived at the motel, Hernandez gave him a bag containing the valium. Defendant put the bag in his truck, but told Hernandez that he didn't have the money at the time and would have to return to make payment. At that point, officers approached Defendant's vehicle to arrest him, but Defendant attempted to flee in his truck. Defendant crashed into another vehicle in the parking lot and was subsequently arrested.
Shortly after Defendant's arrest, Detective Shapiro drove Defendant's truck to a nearby police facility. Once at the facility, Detective Shapiro conducted an inventory of the Defendant's truck. During the inventory of items in the truck, Detective Shapiro found a suitcase. The detective opened the suitcase, finding approximately $30,000.
Defendant was charged with Dealing a Schedule IV Controlled Substance, a class
Defendant filed a motion to suppress the evidence of the $30,000 found in the suitcase, contending that Detective Shapiro conducted an illegal search of his vehicle at the police facility. The prosecution argued that the search fell under the "inventory exception" to the warrant requirement, and that it was also valid as a search incident to an arrest and the "automobile exception" to the warrant requirement. The trial court denied Defendant's motion to suppress on the grounds that it was valid under the automobile exception to the warrant requirement. Having found the search valid on those grounds, the trial court did not reach the issue of whether the evidence was obtained as a result of a valid inventory.
Defendant filed a motion to certify the issue for interlocutory appeal, which the trial court granted. On appeal, the Court of Appeals reversed the trial court, finding that the automobile exception to the warrant requirement did not apply. See Ratliff v. State, 753 N.E.2d 38, 45 (Ind.Ct.App. 2001). The Court of Appeals ordered the case remanded to the trial court to determine whether the search of Defendant's vehicle was conducted as a result of a proper inventory.
Discussion
As an appellate court, we may affirm a trial court's judgment on any theory...
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Clark v. State, No. 48S00-0205-CR-270.
...State points out that an appellate court may affirm a trial court's judgment on any theory supported by the evidence. Ratliff v. State, 770 N.E.2d 807, 809 (Ind.2002) (citation omitted). The State argues that Watson's statement was nevertheless admissible 808 N.E.2d 1189 under Evidence Rule......
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Osborne v. State, No. 29A02–1511–CR–1931.
...decision to combat that threat by impoundment was in keeping with established departmental routine or regulation.’ ” Ratliff v. State, 770 N.E.2d 807, 809–10 (Ind.2002) (ellipsis in original) (quoting Woodford, 752 N.E.2d at 1281 ) (internal quotation marks omitted).16] In the present case,......
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Edmond v. State , No. 49A04–1012–CR–756.
...the State has the burden of proving that an exception to the warrant requirement existed at the time of the search.” Ratliff v. State, 770 N.E.2d 807, 809 (Ind.2002) (citation omitted). There are two levels of police investigation that implicate the Fourth Amendment: First, the Fourth Amend......
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Wilkinson v. State, Court of Appeals Case No. 74A05-1603-CR-741
...402an appellate court, we will sustain the trial court if it can be done on any legal ground apparent in the record. Ratliff v. State, 770 N.E.2d 807, 809 (Ind. 2002). We find here that the search of the vehicle and Wilkinson's person was justified under the medical assistance and automobil......
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Clark v. State, 48S00-0205-CR-270.
......However, the State points out that an appellate court may affirm a trial court's judgment on any theory supported by the evidence. Ratliff v. State, 770 N.E.2d 807, 809 (Ind.2002) (citation omitted). The State argues that Watson's statement was nevertheless admissible 808 N.E.2d 1189 ......
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Osborne v. State
...decision to combat that threat by impoundment was in keeping with established departmental routine or regulation.’ ” Ratliff v. State, 770 N.E.2d 807, 809–10 (Ind.2002) (ellipsis in original) (quoting Woodford, 752 N.E.2d at 1281 ) (internal quotation marks omitted).16] In the present case,......
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Edmond v. State
...the State has the burden of proving that an exception to the warrant requirement existed at the time of the search.” Ratliff v. State, 770 N.E.2d 807, 809 (Ind.2002) (citation omitted). There are two levels of police investigation that implicate the Fourth Amendment: First, the Fourth Amend......
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Wilkinson v. State, Court of Appeals Case No. 74A05-1603-CR-741
...402an appellate court, we will sustain the trial court if it can be done on any legal ground apparent in the record. Ratliff v. State, 770 N.E.2d 807, 809 (Ind. 2002). We find here that the search of the vehicle and Wilkinson's person was justified under the medical assistance and automobil......