State v. Lee

In State v. Lee, 191 Ariz. 542, 544,10, 959 P.2d 799, 801 (1998) the drug courier profile evidence focused on the fact that defendant was carrying a hard-sided plastic suitcase; taking a flight to Chicago, which was known as a "very high demand area for shipment of illegal drugs from Arizona"; and had checked in late for his flight, a common practice of people transporting drugs from the Phoenix airport. Lee, 191 Ariz. at 545,13, 959 P.2d at 802. As the court noted in Lee, drug courier profile evidence may be properly admitted at a suppression hearing to determine whether reasonable suspicion exists for a stop. Id. at11. Drug courier profile evidence, however, is inadmissible at trial as substantive evidence of a defendant's guilt. Id. at 545-46,14-18, 959 P.2d at 802-03 . In Lee, the court held that such evidence is unduly prejudicial because it impermissibly suggests to the jury that "because someone shares characteristics - many of them innocent and commonplace - with a certain type of offender, that individual must also" be guilty. Id. at 545,12, 14, 959 P.2d at 802.