Kansas v. Glover, 140 S. Ct. 1183

Background

Deputy Mark Mehrer observed a 1995 Chevrolet pickup with Kansas plate 295ATJ, ran the plate, and confirmed the registration matched the observed truck.
The Kansas Department of Revenue record showed the truck was registered to Charles Glover Jr., whose Kansas driver's license was revoked.
Mehrer assumed the registered owner was the driver, observed no traffic infractions, and initiated a traffic stop based solely on the revoked-license record.
The driver stopped was Glover; evidence from the stop led to charge of driving as a habitual violator.
Procedural history: District Court suppressed; Kansas Court of Appeals reversed; Kansas Supreme Court reinstated suppression; U.S. Supreme Court granted certiorari and reversed the Kansas Supreme Court, holding the stop reasonable under the Fourth Amendment.
The Court emphasized a narrow holding: a stop is reasonable where an officer lacks information negating a commonsense inference that the registered owner is the driver; additional facts could dispel suspicion.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a stop is reasonable when an officer runs a plate that shows the registered owner has a revoked license and infers the owner is the driver	Glover: inference is a mere "hunch"; no reasonable suspicion without particularized facts about the driver	State: matching plate + registration linking to revoked owner gives reasonable, commonsense suspicion owner may be driving	Stop is reasonable where officer has no information negating the inference owner = driver; reversal of Kansas Supreme Court affirmed
Whether reasonable suspicion must be grounded in an officer's law-enforcement training/experience	Glover/dissent: reasonable suspicion should rest on officer experience and articulated inferences, not judicial common sense	State/Court: common-sense inferences available to ordinary people suffice; specialized training not required in every case	Court: officers may rely on ordinary common-sense inferences; training/experience not a prerequisite
Whether reliance on probabilities or class-based inferences undermines individualized suspicion	Glover/dissent: allowing probabilistic inferences flips burden to the defendant and erodes individualized-suspicion requirement	State: combining database facts with commonsense probabilities is consistent with precedent and still individualized here	Court: probabilities plus specific facts (plate match and revoked owner) can provide reasonable suspicion; holding narrowly limited and subject to rebuttal by additional facts

Key Cases Cited

United States v. Cortez, 449 U.S. 411 (1981) (reasonable suspicion requires particularized, objective basis)
Terry v. Ohio, 392 U.S. 1 (1968) (permits brief investigative stops on reasonable suspicion)
Prado Navarette v. California, 572 U.S. 393 (2014) (commonsense judgments and inferences may inform reasonable suspicion)
United States v. Sokolow, 490 U.S. 1 (1989) (may rely on probabilities and ordinary inferences)
Alabama v. White, 496 U.S. 325 (1990) (reasonable suspicion may be established with different quantity/content of information than probable cause)
Illinois v. Wardlow, 528 U.S. 119 (2000) (commonsense interpretation of evasive behavior)
Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable is not perfect; courts evaluate totality of circumstances)
Delaware v. Prouse, 440 U.S. 648 (1979) (States' interest in ensuring licensed drivers; traffic-stop Fourth Amendment context)
United States v. Arvizu, 534 U.S. 266 (2002) (reasonable suspicion is a low threshold; courts credit commonsense inferences)
United States v. Brignoni-Ponce, 422 U.S. 873 (1975) (stops must not rest solely on group characteristics)
Florida v. Harris, 568 U.S. 237 (2013) (gaps in inference may be overcome by strong indicia of reliability)
Ornelas v. United States, 517 U.S. 690 (1996) (reasonable-suspicion analysis viewed through lens of law enforcement expertise, but not limited to it)