FUENTES v. STATE
2021 OK CR 18
Okla. Crim. App.2021Background
- On July 16, 2016, Sgt. John Ricketts stopped Pedro Fuentes on I‑40 for speeding and improper lane‑change signaling; a K9 alerted and officers seized ~4,441 grams of methamphetamine; Fuentes admitted the items were his.
- Prior investigation: Det. Chad Cook received reliable CI tips that Fuentes and family trafficked meth, observed meth/money at Fuentes’ residence, and obtained a warrant to install an electronic tracker on Fuentes’ car.
- The tracker showed a trip to Phoenix (a known drug distribution hub); Cook and task‑force members surveilled the return trip and notified Oklahoma City officers (including Ricketts) of the vehicle, tag, and that Fuentes was suspected of returning with a drug load.
- Ricketts was asked to stop the car if traffic violations were observed; after issuing the citation he delayed release while a K9 was brought to sniff the vehicle, resulting in the seizure.
- Fuentes moved to suppress, arguing Ricketts lacked personal reasonable suspicion to extend the stop and could not rely on Cook’s information; the district court denied suppression and the Court of Criminal Appeals affirmed.
- Legal question resolved: whether the collective‑knowledge (fellow‑officer) doctrine permits imputing Detective Cook’s reasonable suspicion to Sgt. Ricketts to justify prolonging the traffic stop for a K9 sniff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an officer who stops a vehicle may lawfully extend the stop based on reasonable suspicion held by another officer (learned before the stop) | Fuentes: Ricketts lacked personal reasonable suspicion to detain him beyond issuance of the citation and could not rely on Cook’s out‑of‑sight investigation to extend the stop | State: Under the collective‑knowledge / fellow‑officer doctrine Cook’s reasonable suspicion is imputed to Ricketts, so the extension for a K9 sniff was justified | Court: Affirmed — Cook had reasonable suspicion from CI and investigation; that suspicion was imputed to Ricketts; detaining Fuentes for a K9 sniff was lawful |
Key Cases Cited
- Holt v. State, 506 P.2d 561 (Okla. Crim. App. 1973) (recognizes fellow‑officer rule allowing imputed knowledge among officers)
- State v. Iven, 335 P.3d 264 (Okla. Crim. App. 2014) (examines and applies collective‑knowledge doctrine in Oklahoma)
- Adams v. Williams, 407 U.S. 143 (U.S. 1972) (an officer may act on information supplied by another in forming reasonable suspicion)
- Hensley v. United States, 469 U.S. 221 (U.S. 1985) (officers need not cross‑examine fellow officers about the foundation for transmitted information)
- Arizona v. Arvizu, 534 U.S. 266 (U.S. 2002) (use totality of the circumstances to assess reasonable suspicion)