Ollin Driggers v. Commonwealth of Kentucky, 2025-CA-1081

Driggers was arrested after a controlled buy and a subsequent stop of his car led to seizure of multiple suspected drugs and cash, including marked buy money. 1
A Greenup County grand jury indicted Driggers on five trafficking counts, and he moved to suppress all evidence from the search. 2
At the suppression hearing, Officer Stamper testified that the sheriff maintained surveillance after the controlled buy and relayed information to Stamper to initiate the stop. 3
The circuit court found reasonable suspicion to extend the stop and probable cause for the seizure, and denied suppression. 4
Driggers entered a conditional guilty plea to three trafficking counts and received a six-year sentence, preserving his suppression issue for appeal. 5

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court relied on facts outside the suppression hearing record 6	Driggers said the court used the KYIBRS report, not testimony.	The Commonwealth said the challenged facts came from Officer Stamper's testimony.	No clear error; the testimony supported the court's findings. 7
Whether officers had probable cause or reasonable suspicion to stop Driggers 8	Driggers argued Stamper lacked both probable cause and reasonable suspicion.	The Commonwealth relied on the controlled buy and collective knowledge.	The stop was supported by probable cause and at least reasonable suspicion. 9
Whether the detention was impermissibly prolonged for a canine sniff 10	Driggers claimed the officers unlawfully delayed the stop for the dog.	The Commonwealth said the officers diligently pursued a drug investigation.	The detention was not unreasonably prolonged. 11

Turley v. Commonwealth, 399 S.W.3d 412 (Ky. 2013) (suppression rulings reviewed for clear error and de novo law application 12)
Commonwealth v. Whitmore, 92 S.W.3d 76 (Ky. 2002) (clear-error review requires substantial evidence 13)
Moore v. Asente, 110 S.W.3d 336 (Ky. 2003) (defines clearly erroneous factual findings 14)
Commonwealth v. Pride, 302 S.W.3d 43 (Ky. 2010) (de novo review of law applied to facts after supported findings 15)
Commonwealth v. Priddy, 184 S.W.3d 501 (Ky. 2005) (record materials used by parties and not objected to may be considered 16)
Baltimore v. Commonwealth, 119 S.W.3d 532 (Ky. App. 2003) (probable cause, reasonable suspicion, and seizure standards 17)
Williams v. Commonwealth, 364 S.W.3d 65 (Ky. 2011) (reasonable suspicion for an investigatory stop 18)
Commonwealth v. Bucalo, 422 S.W.3d 253 (Ky. 2013) (detention length depends on diligent pursuit of investigation 19)
Commonwealth v. Clayborne, 635 S.W.3d 818 (Ky. 2021) (traffic-stop prolongation analysis focuses on unrelated tasks adding time 20)
Lamb v. Commonwealth, 510 S.W.3d 316 (Ky. 2017) (collective knowledge doctrine allows reliance on fellow officers' information 21)
Commonwealth v. Blake, 540 S.W.3d 369 (Ky. 2018) (collective knowledge doctrine may support reasonable suspicion 22)