540 S.W.3d 369
Mo. Ct. App.2018Background
- In January 2014 a Kentucky State Police detective (Shoemaker) ran two controlled buys at a suspected dealer's home using a confidential informant (CI); on both occasions a red Hyundai associated with Donna Blake arrived and met briefly with the dealer.
- After the first buy the detective confirmed the Hyundai was registered to Blake and learned the CI said Blake supplied pills to the dealer.
- Before the second buy the detective asked Central City Sgt. Jenkins to stop the Hyundai if it was involved; after the second controlled buy Jenkins stopped Blake at dusk for an allegedly unlit license plate.
- Blake immediately consented to a search; officers found cash and methamphetamine and arrested her.
- Blake moved to suppress, arguing the license-plate statute did not require illumination at the time of the stop (sunset was 5:08 p.m.; stop at 5:16 p.m.), so the stop lacked legal basis.
- The trial court denied suppression, finding Shoemaker had reasonable suspicion of Blake’s involvement in trafficking and that suspicion imputed to Sgt. Jenkins under the collective-knowledge doctrine; the Court of Appeals reversed. The Kentucky Supreme Court granted review and reversed the Court of Appeals, reinstating conviction and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was supported by reasonable suspicion via the collective-knowledge doctrine | Blake: Jenkins stopped her for an invalid license-plate violation; Jenkins did not rely on Shoemaker’s information, so there was no reasonable suspicion | Commonwealth: Shoemaker had reasonable suspicion from the controlled buys and CI information, and that suspicion imputed to Jenkins justifying the stop | The Court held reasonable suspicion existed under the totality of circumstances and Shoemaker’s suspicion imputed to Jenkins; suppression not required |
| Whether an officer’s subjective reasons for a stop defeat an otherwise objectively reasonable basis | Blake: Jenkins’s stated subjective reason (plate light) controls and was invalid | Commonwealth: Fourth Amendment is judged objectively; subjective intent is irrelevant if the circumstances justify the stop | The Court held subjective motivation is irrelevant; objective justification suffices (citing Lamb and Terry) |
Key Cases Cited
- Hensley v. United States, 469 U.S. 221 (1985) (investigatory stop based on another agency’s articulable grounds is permissible)
- Lamb v. Commonwealth, 510 S.W.3d 316 (Ky. 2017) (subjective intent irrelevant; objective reasonableness governs stops)
- Terry v. Ohio, 392 U.S. 1 (1968) (police may make brief investigatory stops on reasonable, articulable suspicion)
- United States v. Hurst, 228 F.3d 751 (6th Cir. 2000) (reasonable suspicion standard and related precedent on investigatory stops)