State v. Carlton
297 Kan. 642
Kan.2013Background
- Carlton was stopped for expired tags; police learned his driving privileges were revoked and he was arrested.
- During the arrest, officers searched Carlton’s truck incident to arrest and found methamphetamine, marijuana, and paraphernalia.
- The district court denied suppression, but after the Gant decision, Carlton moved to suppress again.
- The Court of Appeals reversed, holding the good-faith exception applied because officers reasonably relied on K.S.A. 22-2501(c).
- Dissent argued suppression was required; Carlton sought review on retroactivity, Krull reliance, and Henning’s effect on the statute.
- This court granted review and held the good-faith exception applies; remanded; judgment of the Court of Appeals affirmed and district court reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the good-faith exception apply here? | Carlton: retroactivity blocks, suppression required | State: good-faith applies under Krull-based framework | Yes; good-faith exception applies |
| Is retroactivity governing Gant applicable to suppression? | Carlton: Gant retroactivity requires suppression | State: Davis governs retroactivity for good-faith remedy; no suppression | No suppression; retroactivity resolved by Davis |
| Was reliance on Krull proper to apply good-faith exception here? | Carlton: Krull reliance misapplied | State: Daniel confirms Krull-based good-faith framework | Proper to rely on Krull framework for good-faith |
| Did Henning revive an earlier statute version affecting reasonableness of reliance? | Carlton: Henning revived version negating validity | State: objectively reasonable reliance on statute as it existed | Objectively reasonable to rely on the statute as it existed |
| Should the district court’s suppression ruling be reversed? | Carlton: suppression warranted | State: good-faith exception defeats suppression | District court’s suppression reversed; remanded |
Key Cases Cited
- State v. Dennis, 297 Kan. 229 (2013) (recognizes good-faith exception in Kansas follows Krull framework)
- State v. Daniel, 291 Kan. 490 (2010) (adopts Krull-based good-faith exception for pre-Gant searches)
- State v. Henning, 289 Kan. 136 (2009) (invalidates K.S.A. 22-2501(c) under Gant)
- Gonzales, 578 F.3d 1130 (9th Cir. 2009) (retroactivity discussion cited by Carlton; not controlling here)
- Davis, 131 S. Ct. 2419 (2011) (good-faith exception applicable to searches later deemed illegal by Gant)
- Gant, 556 U.S. 332 (2009) (defines limits on warrantless vehicle searches incident to arrest)
- Krull, 480 U.S. 340 (1987) (good-faith reliance on statutory authority before an invalidation)
- Davis, 564 U.S. 229 (2011) (detailing proper analysis of good-faith in suppression remedies)