People v. Mickens

1 Citing case

  1. People v. Rodriguez

    945 P.2d 1351 (Colo. 1997)   Cited 69 times
    Comparing Sharpe , 470 U.S. at 683, 105 S.Ct. 1568 (twenty-minute detention was reasonable); with Place , 462 U.S. at 709–10, 103 S.Ct. 2637 (ninety-minute detention of suspect’s luggage was "prolonged" and exceeded scope of stop); and People v. Hazelhurst , 662 P.2d 1081, 1086 (Colo. 1983) (twenty- to thirty-minute detention exceeded scope of stop); and People v. Mickens , 734 P.2d 646, 649 (Colo. App. 1986) (one-and-one-half-hour detention exceeded scope of stop)

    Third, whether the suspect was required to move from one location to another. See Florida v. Royer, 460 U.S. 491, 504 (1983) (moving suspect from one location to another during an investigatory stop, in absence of safety and security reasons, exceeded scope of stop); People v. Mickens, 734 P.2d 646, 649 (Colo.App. 1986); see generally 4 LaFave, supra 9.2(g). Fourth, whether there were alternative, less intrusive means available and "whether the police acted unreasonably in failing to recognize or to pursue [them]."