State v. Trujillo

In State v. Trujillo, 739 P.2d 85 (Utah Ct. App. 1987), an officer detained three individuals who had been "peering" into store windows at approximately 3:30 a.m. 739 P.2d at 86. The court of appeals concluded that the only facts offered in support of the detention were the late hour, the fact that the individuals appeared nervous and were in a high-crime area, and the presence of a "suspicious" knapsack. Id. at 86, 89. Although the court concluded that the detention in that case was not justified by reasonable suspicion, it twice pointed out that the detaining officer had not received any reports of criminal activity in the area that day. Id.