Filed 6/18/26 P. v. Mahaffey CA2/6
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION SIX
THE PEOPLE, 2d Crim. No. B346226
(Super. Ct. No. 2022030808)
Plaintiff and Respondent, (Ventura County)
v.
TYE GARRET MAHAFFEY,
Defendant and Appellant.
Tye Garret Mahaffey appeals a judgment following his
conviction for identity theft. (Pen. Code, § 530.5.) He claims the
trial court erred by denying his motion to suppress pursuant to
Penal Code section 1538.5. We conclude, among other things,
that the police did not unlawfully prolong a traffic stop and the
trial court did not err by denying appellant’s motion. We affirm.
FACTUAL AND PROCEDURAL HISTORY
On November 28, 2022, the police received a call that there
was a person in a white Ford Escape vehicle that was outside of a
house known for drug activity in the past.
Sheriff deputy Justin Lopez responded to the scene and saw the
vehicle leaving that area.
Lopez typed the license plate number of the vehicle into his
computer which showed the registration for that vehicle had
expired. The license plate had an orange 2023 “DMV sticker” on
it which appeared to be fake or stolen. He conducted “a traffic
enforcement stop.”
Appellant, who was driving, stopped the vehicle. When
Lopez asked him for his driver’s license, appellant said “he didn’t
have his physical license on him,” but he gave Lopez his driver’s
license number. Appellant gave Lopez his “registration
paperwork.”
About one minute into the stop, Lopez noticed appellant
appeared to show “objective signs and symptoms” of a person who
was under the influence of a controlled substance. Lopez asked
appellant if he would take a drug-abuse recognition (DAR)
evaluation to confirm whether he was under the influence of
narcotics. Appellant refused multiple times.
Lopez conducted a records check which showed appellant’s
vehicle registration was current. He called for another officer to
assist him at the scene. Officer Henry White arrived in five to
seven minutes. At ten minutes after the traffic stop, Lopez asked
appellant to get out of the car. Lopez arrested appellant about 15
minutes after the traffic stop for being under the influence of a
controlled substance.
Following the arrest, deputies searched the vehicle and
found a backpack containing a driver’s license showing
appellant’s photo with a different first and last name on the card.
The backpack also contained 62 “OxyContin counterfeit pills,” a
bag containing what appeared to be 1.8 grams of
2
methamphetamine, and heroin. In a search of the trunk of the
vehicle, deputies found four boxes of shotgun shells. At the police
station appellant admitted he was a convicted felon.
The People charged appellant with being a felon in
possession of ammunition (Pen. Code, § 30305, subd. (a)(1); count
1), identity theft (id., § 530.5, subd. (c)(1); count 2), possession of
heroin (Health & Saf. Code, § 11350, subd. (a); count 3) and
possession of methamphetamine (id., § 11377, subd. (a); count 4.)
Appellant pled not guilty.
Prior to the preliminary hearing appellant filed a motion to
suppress pursuant to Penal Code section 1538.5. At the
preliminary hearing Lopez testified. Appellant was held to
answer and the motion was denied. His renewed motion to
suppress was denied.
Appellant thereafter pled guilty to count 2 identity theft, a
misdemeanor, the other counts were dismissed. He was placed
on one year probation.
DISCUSSION
Prolonged Detention
Appellant contends the trial court erred by denying his
section 1538.5 motion because he was “impermissibly detained
past the time needed to handle the” investigatory traffic stop. He
claims he was unlawfully detained “after the responding officers
determined that his vehicle registration was valid.”
“[C]hallenged searches and seizures under the Fourth
Amendment are ordinarily analyzed ‘under a standard of
objective reasonableness without regard to the underlying intent
or motivation of the officers involved.’ ” (People v. Ramirez (2024)
104 Cal.App.5th 315, 329 (Ramirez).) “An investigatory stop
exceeds constitutional bounds when extended beyond what is
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reasonably necessary under the circumstances that made its
initiation permissible.” (People v. Russell (2000) 81 Cal.App.4th
96, 101 (Russell).) “Circumstances which develop during a
detention may provide reasonable suspicion to prolong the
detention.” (Id., at p. 102.) “There is no set time limit for a
permissible investigative stop; the question is whether the police
diligently pursued a means of investigation reasonably designed
to confirm or dispel their suspicions quickly.” (Ibid.)
“On review of denial of a suppression motion, we defer to
the trial court’s factual findings where supported by substantial
evidence, but exercise independent judgment to determine
whether, on the facts found, the search was reasonable under
Fourth Amendment standards.” (Russell, supra, 81 Cal.App.4th
at p. 102.)
Lopez was an officer who had experience in identifying
people who had used narcotics. Within one minute after the
traffic stop, Lopez had reasonable suspicion to believe that
appellant was impaired by being under the influence of narcotics.
He testified that about a minute into the stop appellant’s pupils
“were extremely pinpointed,” his lips were dry and “chappy,” and
appellant was nervous. He was sweating. His eyelids were
“droopy” and his speech “was a little bit slurred and slow.” His
statements to Lopez became defensive. The fingertips on
appellant’s hands “were burnt and kind of dry which is typical . . .
when individuals use methamphetamine, when they smoke the
methamphetamine pipe.” He was near a house known for
repeated “drug activity.”
Lopez told appellant about his “objective signs and
symptoms” of intoxication and that “it could be dangerous” to
“drive under those conditions.”
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Those objective signs of drug intoxication supported
reasonable suspicion to continue the detention and prevent him
from driving. (Russell, supra, 81 Cal App.4th at p. 102; People v.
Campuzano (2015) 237 Cal.App.4th Supp. 14, 21 (Campuzano).)
Because appellant did not have his driver’s license, Lopez could
“reasonably expand the scope of the stop” to verify his identity.
(People v. Miranda (1993) 17 Cal.App.4th 917, 927.) Because he
believed appellant’s car displayed a fake registration sticker, a
criminal offense, (Veh. Code, §§ 4462, 4462.5), he could take
additional time to investigate this issue.
Lopez decided to have appellant exit his vehicle because
inter alia, he had been near a known “drug house.” Given this
location’s criminal history, he could reasonably believe he had to
proceed with caution. (People v. Valle (2024) 105 Cal.App.5th
195, 202-203 (Valle).) He requested an additional officer to come
to the scene. It took officer White five to seven minutes to arrive
there. Lopez testified the presence of the second officer was
necessary for “officer safety.” “Officer safety is a legitimate and
important governmental interest to consider in Fourth
Amendment analysis.” (People v. Hart (1999) 74 Cal.App.4th
479, 490.) A “ ‘brief continuation of [the] detention for officer
safety” is not unconstitutional. (Ramirez, supra, 104 Cal.App.5th
at p. 327-328.) This five-to-seven-minute delay was not
unreasonable. (Valle, supra, 105 Cal.App.5th at p. 201.)
After the second officer arrived, appellant got out of the
vehicle. Lopez spent a total of 10 minutes making numerous
efforts to get appellant to consent to take a DAR evaluation to
determine whether he was under the influence of narcotics.
Appellant repeatedly refused to engage in drug abuse evaluation
testing. Lopez then placed him under arrest.
5
Appellant notes that before the police removed him from
his car the police had confirmed that his registration was valid.
He argues that because the reason for the traffic stop involved
the registration, he should have been allowed to drive away after
the police determined that his registration was valid.
But well before the police determined the validity of the
registration, Lopez had reasonable suspicion to detain him one
minute after the stop because of his objective signs of being under
the influence which made him unsafe to drive. The
determination that his registration was valid did not mean that it
was safe for him to drive away. “[T]here was no prolonged
detention because immediately after the stop and detention
. . . the officer observed the defendant’s objective symptoms of
drug intoxication . . . .” (Campuzano, supra, 237 Cal.App.4th
Supp. at p. 21.)
The traffic stop from “the point of initial contact to the
point of arrest” was “about 15 minutes.” This was not an
unreasonably prolonged detention given the facts of this case.
(People v. Torres (2010) 188 Cal.App.4th 775, 786; United States
v. Williams (10th Cir. 2001) 271 F.3d 1262, 1271.)
Unlawful Arrest
Appellant contends his arrest was unlawful. We disagree.
Lopez had probable cause to arrest him. Appellant’s
objective physical symptoms of intoxication included slurred
speech, droopy eyelids, pinpoint pupils, a nervous demeanor,
sweating, dry lips, burnt methamphetamine type fingertips
coupled with the fact he was leaving the area of a house known
for repeated drug transactions. The combination of these factors
supported probable cause to believe appellant was under the
influence of a controlled substance. (People v. Guajardo (1994) 23
6
Cal.App.4th 1738, 1742-1743; People v. Sanchez (1987) 195
Cal.App.3d 42, 45, 48; People v. Jones (1987) 189 Cal.App.3d 398,
405-406.) Moreover, his repeated refusal to take a drug test is
“reasonably interpreted as a consciousness of guilt” given his
intoxicated state, and it provided further “probable cause.”
(Marvin v. Dep’t of Motor Vehicles (1984) 161 Cal.App.3d 717,
720; see also People v. Zavala (1966) 239 Cal.App.2d 732, 740.)
Officer Lopez’s Credibility
Appellant contends Lopez’s credibility was impeached by
the bodycam video evidence.
On a motion to suppress, the trial court exclusively decides
the credibility of the witnesses and resolves conflicts in the
evidence. (People v. Tully (2012) 54 Cal.4th 952, 979 (Tully);
People v. Woods (1999) 21 Cal.4th 668, 673.) Here the court
found Lopez was credible and the bodycam evidence did not
undermine his testimony. It said, “you can’t see from the body
cam necessarily what the officer is seeing up at the scene.” There
was a “disconnect” between “where the body cam is positioned
versus where the officer’s eyes are . . .”
These findings are supported by the record. The bodycam
video shows Lopez was in a closer and better position to directly
see into the vehicle and observe appellant. The side angle view
from the bodycam did not provide such a direct view into the car.
(See State v. Harbach (2024) 3 N.W.3d 209, 221-222.) At times,
part of the driver’s side car door blocked part of the video view of
appellant inside the car. The trial court could reasonably decide
to give greater weight to Lopez’s testimony than the video
evidence. “Even though bodycam footage can be useful, courts
should be careful in relying on the footage when determining
specific facts that are not easily observable from the video.”
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(Id., at p. 222.) Moreover, the court saw Lopez testify and found
him to be credible. Appellant has not shown error. (Tully, supra,
54 Cal.4th at p. 979.)
Appellant’s remaining contentions do not support grounds
for reversal.
DISPOSTION
The judgment is affirmed.
NOT TO BE PUBLISHED.
YEGAN, Acting P. J.
We concur:
BALTODANO, J.
CODY, J.
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Russel-Paul H. Kawai, Judge
Superior Court County of Ventura
______________________________
Claudia Y. Bautista, Public Defender, William Quest,
Deputy Public Defender, for Defendant and Appellant.
Rob Bonta, Attorney General, Charles C. Ragland, Chief
Assistant Attorney General, Susan Sullivan Pithey, Assistant
Attorney General, Scott A. Taryle and Sophia A. Lecky, Deputy
Attorneys General, for Plaintiff and Respondent.