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FUENTES v. STATE
517 P.3d 971
| Okla. Crim. App. | 2021
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Background

  • 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).
Read the full case

Case Details

Case Name: FUENTES v. STATE
Court Name: Court of Criminal Appeals of Oklahoma
Date Published: Jul 15, 2021
Citation: 517 P.3d 971
Court Abbreviation: Okla. Crim. App.