When reviewing a motion to suppress evidence, how do we review the findings of the trial court?

California, United States of America


The following excerpt is from People v. Rosales, B292532 (Cal. App. 2019):

When reviewing a trial court decision on a motion to suppress evidence, we defer to the trial court's factual findings if supported by substantial evidence. (People v. Evans (2011) 200 Cal.App.4th 735, 742.) We then apply the law to those facts and make an independent decision as to whether a search or seizure was reasonable under the Fourth Amendment. (Ibid.) "We will affirm the trial court's ruling if it is correct on any theory of law applicable to the case, even if for reasons different than those given by this court." (Ibid.)

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