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STATE of Louisiana v. Arial VALENCIA-LACAYO
Writ granted. A trial court is afforded great discretion when ruling on a motion to suppress, and its ruling will not be disturbed absent abuse of that discretion. State v. Wilder, 09-2322, p. 2 (La. 12/18/09), 24 So. 3d 197, 198. “When a trial court makes findings of fact based on the weight of the testimony and the credibility of the witnesses, a reviewing court owes those findings great deference, and may not overturn those findings unless there is no evidence to support those findings.” State v. Thompson, 11-0915, pp. 13-14 (La. 5/8/12), 93 So. 3d 553, 563 (quoting State v. Wells, 08-2262, p. 4 (La. 7/6/10), 45 So. 3d 577, 580).
In this matter, after the hearing on the motion to suppress, the trial court issued a per curiam, observing that, “[a]s the trier of fact,” it had “to determine the credibility of witnesses and the weight their testimony deserves.” Finding the witnesses in this case to be credible, the trial court found sufficient information to establish probable cause. Based on the record before us, we find no abuse of the trial court's discretion and we find the court of appeal erred in substituting its findings for those of the trial court. Accordingly, the court of appeal's ruling is reversed, and the trial court's judgment denying the motion to suppress is reinstated. The case is remanded to the district court for further proceedings
I agree with the Court's opinion to reinstate the trial court decision denying this motion to suppress. In State v. Edwards this Court held that “[t]he observations and reports of fellow police officers who are engaged in related investigations can provide reasonable basis for an arrest.” see State v. Edwards, 406 So.2d 1331, 1338 (La. 1981). Accord, State v. Pratt, 16 So.3d 1163 (La. 2009) (probable cause or reasonable suspicion may rely on the collective knowledge possessed by all of the police involved in the investigation). The trial court correctly found the officer relied upon collaborative information from his supervisor.
PER CURIAM
Hughes, J., Dissents and would deny the writ. Crain, J., concurs for the reasons assigned by Justice Cole. Griffin, J., Dissents and would deny the writ. Guidry, J., Dissents and would deny the writ. Cole, J., concurs and assigns reasons.
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Docket No: No. 2025-KK-01296
Decided: October 18, 2025
Court: Supreme Court of Louisiana.
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