John Canada v. United States

This case presents a significant and recurring question about the standard of appellate review of a district court’s ruling on a motion to suppress evidence, on which the courts of appeals are deeply divided. In Ornelas v. United States, 517 U.S. 690 (1996), this Court granted certiorari to resolve this issue and explicitly held that the court of appeals should review the district court’s factual findings for clear error; “give due weight to inferences drawn from those facts by resident judges and local law enforcement officers”; and decide whether reasonable suspicion or probable cause exists de novo. Id. at 699. Despite that clear guidance, the Tenth Circuit and other courts of appeals have added a layer of deference to the prosecution by reviewing the evidence in a suppression-hearing record in the “light most favorable to the government.” This case presents the following issue: Whether the review of the evidence in a suppression-hearing record “in the light most favorable to the government” conflicts with Ornelas’s standard of review and impermissibly places a thumb on the scales in favor of the prosecution in resolving Fourth Amendment claims.