State v. Daniel
242 P.3d 1186
Kan.2010Background
- Daniel was convicted of possession of methadone found during a warrantless search of her vehicle after arrest for driving with a suspended license.
- The district court upheld the search as incident to arrest under K.S.A. 22-2501(c), limiting the search to discovering fruits, instrumentalities, or evidence of a crime.
- The statute 22-2501(c) was later held unconstitutional by Henning, which applied Gant narrowing the vehicle exception.
- The State sought to preserve the conviction under a good-faith exception to the exclusionary rule.
- The Kansas Supreme Court, applying Krull-style reasoning, held the officer could reasonably rely on the statute prior to Gant and affirmed the conviction.
- Daniel’s appeal was timely, and the case was reviewed after Gant and Henning were decided.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a good-faith exception applies to evidence obtained under a statute later found unconstitutional. | Daniel argues no good-faith savings for relying on the statute. | State argues officers reasonably relied on the statute and case law prior to Gant. | Yes; good-faith exception applies to pre-Gant searches. |
| Whether the officer could objectively and reasonably rely on K.S.A. 22-2501(c) to search Daniel’s vehicle and purse. | Daniel contends the statute was unconstitutional at the time of search. | State contends reliance was objectively reasonable due to precedent and legislative history. | Officer could reasonably rely on the statute; search upheld. |
| Whether Krull extends the good-faith exception to statutory reliance in Kansas. | State should not extend Krull to statutory reliance. | Krull applies when reliance on a statute is objectively reasonable. | Krull-based good-faith exception applies in Kansas for statutory reliance. |
| Whether pre-Gant precedent supported the scope of the search at issue. | Daniel argues scope was broader than allowed by Belton/Gant. | State relies on pre-Gant interpretations supporting broader searches. | Pre-Gant precedent supported reasonable reliance on the statute. |
| Whether the legislature abandoned its duty to enact constitutional laws in amending 22-2501(c). | Amendment reflects constitutional scope; no abandonment. | Legislative history shows intent to expand Belton-consistent searches. | Legislature did not abandon its constitutional duty; statute considered valid at the time. |
Key Cases Cited
- State v. Henning, 289 Kan. 136, 209 P.3d 711 (2009) (pre-Gant vehicle search statute interpretation; later reversed on other grounds)
- Gant v. United States, 129 S. Ct. 1710 (U.S. Supreme Court, 2009) (limits on vehicle searches incident to arrest after arrestee leaves vehicle)
- United States v. Krull, 480 U.S. 340 (U.S. Supreme Court, 1987) (good-faith exception for reliance on a statute later found unconstitutional)
- State v. Hoeck, 284 Kan. 441, 163 P.3d 252 (2007) (recognition of good-faith exception in Kansas law)
- State v. Leon, 468 U.S. 897 (U.S. Supreme Court, 1984) (good-faith reliance on a warrant later found defective)
- State v. Davison, 41 Kan. App. 2d 140, 202 P.3d 44 (2009) (pre-Gant vehicle search interpretation in Kansas appellate context)