State v. Chettero

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The Utah Highway Patrol performed a drug interdiction exercise on a rural stretch of the interstate. UHP chose to focus the bulk of its enforcement efforts on cars bearing out-of-state license plates. Defendant's California-plated vehicle was stopped during the exercise, and the traffic stop yielded evidence of illegal drugs. Defendant was charged with possession with intent to distribute. Defendant filed two suppression motions - one based on the Equal Protection Clause and right to travel and the other rooted in the Fourth Amendment. The district court denied both motions, and Defendant entered a conditional guilty plea. On appeal, the Supreme Court affirmed, holding (1) the traffic stop did not restrict Defendant's movement in a manner implicating his fundamental right to travel; (2) because there was a rational basis for UHP's selective enforcement of traffic laws - by choosing to stop vehicles licensed outside of Utah - Defendant's equal protection claim was meritless; and (3) to the extent the district court erred in failing to consider any evidence of relevance to the Fourth Amendment motion to suppress, it was harmless error. View "State v. Chettero" on Justia Law