The Court of Appeals had a relatively quiet January and released four opinions. In one of those decisions, People v. Messano, it considered (1) whether the police had reasonable suspicion to detain the defendant and (2) even if the police lacked reasonable suspicion to detain the defendant, whether the People met their burden of showing that drug-related contraband should not be suppressed because the evidence was in plain view.

In a 4-3 split decision, Judge Jenny Rivera wrote for the majority holding that the search was unconstitutional because the People failed to establish that the police had reasonable suspicion to detain the defendant and failed to show that the police observed the challenged evidence in plain view.