What is the standard of review on appeal from a denial of a motion to suppress?

California, United States of America


The following excerpt is from People v. Najor, E064496 (Cal. App. 2017):

Our standard of review on appeal from the denial of a motion to suppress is well established. "We defer to the trial court's factual findings where supported by substantial evidence, but exercise our independent judgment to determine whether, on the facts found, the search was reasonable under Fourth Amendment standards. [Citation.]" (People v. Brown (1998) 62 Cal.App.4th 493, 496.) "'"The power of the appellate court begins and ends with a determination as to whether there is any substantial evidence, contradicted or uncontradicted," to support the trial court's findings.' [Citations.]" (People v. Snead (1991) 1 Cal.App.4th 380, 384.) "'Reversal is not warranted merely because the circumstances might also be reasonably reconciled with a contrary finding.' [Citation.]" (Ibid.)

3. Analysis.

Both sides agree that the arrest warrant was invalid. Thus, the issue is whether the situation falls within the good faith exception to the exclusionary rule set forth in Leon and Arizona v. Evans (1995) 514 U.S. 1 (Evans).

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