Shannon C. Blankenship v. State of Indiana (mem. dec.)
18A02-1601-CR-196
| Ind. Ct. App. | Jul 25, 2016Background
- In September 2011 Corporal Tony Skinner learned in an investigation that Shannon Blankenship’s driver’s license was suspended as an habitual traffic violator (HTV).
- On February 20, 2012, Skinner observed Blankenship, the sole occupant, get into his car and drive away and initiated a traffic stop based on his prior knowledge of the suspension.
- Blankenship provided name and birthdate but no physical license; dispatch confirmed the license was suspended. He was charged with operating as an HTV (Class D felony).
- Blankenship filed a pretrial motion to suppress, arguing the stop lacked reasonable suspicion because Skinner’s knowledge of the suspension was five months old.
- The trial court denied the motion, concluded the stop was supported by reasonable suspicion under the totality of circumstances, convicted Blankenship after a bench trial, and sentenced him to electronic home detention.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Blankenship) | Held |
|---|---|---|---|
| Whether the traffic stop violated the Fourth Amendment (reasonable suspicion) | Officer’s prior investigation and identification of Blankenship as driver provided reasonable suspicion to stop the vehicle | Prior knowledge of a suspension from five months earlier was stale; officer was required to verify current suspension before stopping | Stop was lawful: totality of circumstances supported reasonable suspicion; evidence admissible |
| Whether Armfield requires contemporaneous verification that the owner’s suspension still exists before stopping | Armfield permits a stop when officer knows owner has suspension and lacks evidence owner is not driver; applies here where officer saw Blankenship enter and drive | Armfield’s “knows” language means contemporaneous knowledge; older information insufficient | Armfield framework applies; here first-prong satisfied given recent investigation and no facts indicating the suspension had been lifted |
Key Cases Cited
- Armfield v. State, 918 N.E.2d 316 (Ind. 2009) (framework: officer has reasonable suspicion when he knows registered owner’s license is suspended and has no reason to believe owner is not driver)
- Holly v. State, 918 N.E.2d 323 (Ind. 2009) (applies Armfield; disparate driver/owner characteristics limit scope of stop)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-circumstances test for reasonable suspicion)
- United States v. Cortez, 449 U.S. 411 (1981) (reasonable suspicion requires particularized and objective basis)
- Hill v. California, 401 U.S. 797 (1971) (reasonableness requires sufficient probability, not certainty)