State of Indiana v. William F. Stevens
33 N.E.3d 1200
Ind. Ct. App.2015Background
- On Jan. 23, 2014, Perry County deputies discovered William Stevens attempted to purchase pseudoephedrine at a Tell City drugstore after checking purchase logs and IDACS records.
- IDACS listed a prior Florida conviction for Stevens as “Poss Meth W Intent to Sell/Manufacture/Deliver,” leading officers to believe Indiana law made his purchase unlawful.
- Deputy Marsh arrested Stevens at the store without a warrant and without administering Miranda warnings; Stevens then admitted he had methamphetamine on his person.
- Officers obtained consent from Stevens’s fiancée to search their home and seized drug paraphernalia; Stevens later confessed ownership at the police station after receiving Miranda warnings.
- Stevens moved to suppress all evidence and statements, arguing the IDACS entry mischaracterized a Florida conviction (for Alprazolam), so there was no probable cause for the arrest. The trial court granted suppression and the State appealed.
- The Court of Appeals reversed, holding officers reasonably relied on IDACS information and that reliance provided probable cause for the warrantless public arrest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers had probable cause to arrest Stevens at the drugstore for illegally possessing/purchasing a precursor | Stevens: IDACS entry was incorrect (conviction was for Alprazolam), so no probable cause; officers should have verified the record before arresting | State: Officers reasonably relied on IDACS; mistakes may occur but reliance on official records gives probable cause; cannot judge with hindsight | Reversed trial court: reasonable to rely on IDACS; probable cause existed for a warrantless public arrest |
Key Cases Cited
- Moody v. State, 448 N.E.2d 660 (Ind. 1983) (officers may rely in good faith on police dispatch/agency information without proving source reliability)
- Santana v. United States, 427 U.S. 38 (1976) (warrantless public-arrest supported by probable cause does not violate Fourth Amendment)
- Hayes v. Florida, 470 U.S. 811 (1985) (distinguishing forcible removal to stationhouse from public-arrest rules)
- Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (Article 1, §11 reasonableness test: balance suspicion, intrusion, and law enforcement needs)
- Row v. Holt, 864 N.E.2d 1011 (Ind. 2007) (officer reasonably believed probable cause existed based on information from another officer even if that information proved incorrect)
- Moore v. United States, 215 F.3d 681 (7th Cir. 2000) (probable cause allows reasonable mistakes by officers)
- Jenkins v. Keating, 147 F.3d 577 (7th Cir. 1998) (information from an apparently credible source can supply probable cause to arrest)