Example Of Argument Paper

I. Defendant alleges the State has made several incorrect assertions.

1. That Detective Kroeger instructed the other officers to initiate a stop of a grey Kia Forte.

The Court State v. Harper determined that officers are allowed to rely on information from other officers in order to acquire reasonable suspicion. 31 S.W.3d 267, 271 (Tenn. Ct. App. 2000). Detective Kroeger had reasonable suspicion regarding the car that dropped off Ms. Hernandez. The fact that he ordered other officers to stop the car does not negate that. The fact that officers planned to stop whatever car dropped off Ms. Hernandez for the prostitution activities is legally inconsequential because it does not affect the analysis of whether officers had reasonable suspicion once the car arrived and dropped off Ms. Hernandez. Furthermore, Ms. Hernandez told Detective Kroeger she was dropped off in a grey car

That the Defendant admitted to smoking marijuana in the vehicle prior to dropping off Ms. Hernandez.

Defendant argues this alleged statement is nowhere in the officer reports or audio recordings. Regardless of this allegation is true, Officer Brooks alleges in her affidavit report that Ms. Hernandez did inform her of this same fact in their conversation. Either way, this information is likely inconsequential because it does nothing to negate the reasonable suspicion acquired by the officers from (1) witnessing Defendant drop off a woman known to law enforcement to be engaging in prostitution and (2) the officers detecting the smell of burnt marijuana from the car upon approach.

3. That Ms. Hernandez acknowledged the Defendant knew she was a prostitute.

This fact is of no legal consequence. Furthermore, it is apparent from the transcripts that Detective Kroeger did not find Ms. Hernandez to be credible and forthcoming in her answers, which in turn gave him more reason to suspect Defendant’s involvement.

4. That the passenger, Ms. Hardey, believed the Defendant was Ms. Hernandez’s