FUENTES v. STATE
517 P.3d 971
| Okla. Crim. App. | 2021Background
- In June 2016 two reliable confidential informants told Detective Chad Cook that Pedro Fuentes and family were trafficking meth; Cook corroborated via a domestic-disturbance call where officers observed meth and cash.
- Cook obtained a warrant to install an electronic tracking device on Fuentes’ car and monitored the vehicle to and from Phoenix, a known drug distribution hub.
- Cook relayed make/model/tag and his suspicion that Fuentes was returning with a drug load and asked local officers to stop the car for observable traffic violations.
- On July 16, 2016 Sgt. John Ricketts observed Fuentes commit traffic violations, stopped him, ran checks, and wrote a ticket; Ricketts retained the driver while calling for backup and a K9.
- A drug dog alerted to the vehicle and officers found ~4,441 grams of meth in a duffel; Fuentes admitted ownership but moved to suppress, arguing the stop was unlawfully extended without reasonable suspicion personal to Ricketts.
- The district court denied suppression; the Oklahoma Court of Criminal Appeals affirmed, holding the collective-knowledge/fellow-officer doctrine allowed Ricketts to rely on Cook’s reasonable suspicion to prolong the stop for a K9 sniff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an officer may extend a traffic stop based on reasonable suspicion known only to other officers (collective-knowledge/fellow-officer rule) | Fuentes: Ricketts lacked personal reasonable suspicion to detain him beyond the traffic-stop purpose; Ricketts could not rely solely on information held by other officers to prolong the stop. | State: Detective Cook had reasonable suspicion from CI information and investigation; under the collective-knowledge doctrine Cook’s suspicion could be imputed to Ricketts who was asked to stop the car. | The court held Cook’s reasonable suspicion was vertically imputed to Ricketts under the collective-knowledge/fellow-officer rule; the extended detention for a K9 sniff was lawful and suppression was not required. |
Key Cases Cited
- Adams v. Williams, 407 U.S. 143 (1972) (officer may act on information supplied by others; no requirement of personal observation).
- Hensley v. United States, 469 U.S. 221 (1985) (officers may act on information from fellow officers without cross‑examining their basis).
- United States v. Arvizu, 534 U.S. 266 (2002) (reasonableness assessed under the totality of the circumstances).
- State v. Iven, 335 P.3d 264 (Okla. Crim. App. 2014) (explaining and applying the collective‑knowledge/fellow‑officer doctrine in Oklahoma).
- Seabolt v. State, 152 P.3d 235 (Okla. Crim. App. 2006) (traffic stop is a seizure; scope and duration must relate to purpose and last no longer than necessary).
- Holt v. State, 506 P.2d 561 (Okla. Crim. App. 1973) (early Oklahoma recognition of the fellow‑officer rule).
- United States v. Whitley, 680 F.3d 1227 (10th Cir. 2012) (distinguishing vertical and horizontal applications of collective knowledge).
