State v. Daniel
242 P.3d 1186
| Kan. | 2010Background
- Daniel was convicted of possession of methadone found during a warrantless search of her car after arrest for driving with a suspended license.
- District court upheld the search as within K.S.A. 22-2501(c)’s scope (to discover fruits, instrumentalities, or evidence of a crime).
- Henning later held K.S.A. 22-2501(c) unconstitutional, applying Gant’s vehicle search rule, which would have excluded the evidence.
- State urged a good-faith exception to the exclusionary rule, based on Krull and Leon, arguing the officer reasonably relied on the statute and then-existing law.
- Kansas Supreme Court held a good-faith exception applies to searches conducted before Gant’s decision (April 21, 2009) when the officer reasonably relied on the statute, appellate decision, and legislative history, and affirmed the conviction.
- Davis, C.J., did not participate; dissent by Johnson, J. would not recognize a statute-based good-faith exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a good-faith exception applies to a statute-based reliance prior to Gant | Daniel’s reliance on the statute was reasonable | State argues Krull-based good-faith applies to statute | Yes, good-faith exception applies; evidence admissible |
| Whether the officer’s reliance on K.S.A. 22-2501(c) was objectively reasonable | Reliance was reasonable due to prior precedent and appellate ruling | Reliance on lower court decisions and statute was not clearly unconstitutional | Yes, relied on statute, case law, and history; reasonable |
| Whether applying the good-faith exception is appropriate given pre-Gant context | Rule should not extend to statutory reliance | Krull-based exception should apply | Applicable; district court’s suppression denial affirmed |
Key Cases Cited
- Texas v. Krull, 480 U.S. 340 (1987) (good-faith exception for reliance on statute)
- United States v. Leon, 468 U.S. 897 (1984) (good-faith reliance on valid warrant)
- Herring v. United States, 555 U.S. 135 (2009) (negligently maintained police records; good-faith extension)
- State v. Hoeck, 284 Kan. 441 (2007) (Kansas case recognizing Krull-based approach)
- State v. Henning, 289 Kan. 136 (2009) (statutory scope of 22-2501(c) before Gant)
- State v. Karson, 235 P.3d 1260 (2010) (Kansas Appellate decision supporting good-faith reliance)
- United States v. McCane, 573 F.3d 1037 (2009) (Tenth Circuit; pre-Gant precedent relied upon)
- Arizona v. Evans, 514 U.S. 1 (1995) (reliance on erroneous court records)
- United States v. Davis, 598 F.3d 1259 (2010) (extension of good-faith to precedents)