State v. Creed, 319 P.3d 80

Officer misread Creed’s license plate as 154 YMK and used WACIC data indicating it was stolen.
The misread plate led to a traffic stop based on false information.
After stopping Creed, the officer discovered the correct plate; Creed waited while he checked it.
During the approach, Creed tossed an item; the officer used a flashlight and observed a tar-like substance in bags, later identified as heroin.
Creed was arrested for possession of heroin after Miranda rights were administered and consent obtained for a search.
The trial court suppressed the heroin, and the State appealed seeking reversal on the stop and subsequent detention grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was reasonable under Terry given the officer’s mistaken belief.	Creed (State) argues reasonable suspicion existed under Snapp.	Creed contends the stop was unlawful due to the officer’s mistaken fact.	No; stop invalid as based on officer’s own mistaken facts.
Whether continued detention after realizing the mistake was lawful.	State contends brief detention can continue to dispel suspicion.	Creed argues continuation after mistake exceeded lawful scope.	Detention extended beyond permissible scope; suppress evidence.
Whether the attenuation doctrine salvages the tainted evidence.	State urges attenuation due to voluntary act of tossing heroin.	Creed argues evidence tainted by unlawful stop cannot be admitted.	Attenuation doctrine does not apply; exclusion upheld.

State v. Snapp, 174 Wn.2d 177 (2012) (reasonable suspicion not contingent on statute violation; headlights case)
State v. Duncan, 146 Wn.2d 166 (2002) (burden to show search/seizure fits warrant exceptions; de novo review)
State v. Day, 161 Wn.2d 889 (2007) (Terry stop requires specific, objective facts indicating possible criminal activity)
State v. Afana, 169 Wn.2d 169 (2010) (rejects good-faith as exception to exclusionary rule; reliance on information must be objective)
State v. Penfield, 106 Wn.App. 157 (2001) (cannot continue stop based on suspect’s status when ownership/driver mismatch evident)
State v. Chatton, 11 Ohio St. 3d 59 (1984) (continuing detention improper when not justified by new grounds)
State v. Gaddy, 152 Wn.2d 64 (2004) (distinguishes reliance on erroneous license information from agency reliability)
State v. O’Cain, 108 Wn.App. 542 (2001) (dispatched information about vehicle not sufficient for stop; limits on reliance)
State v. Bonds, 98 Wn.2d 1 (1982) (exclusionary rule scope; direct reflections on illegality and evidence)