State v. Dennis, 297 Kan. 229

Dennis was convicted on four counts related to meth manufacturing and drug paraphernalia.
The suppression issue involved items seized during a vehicle search incident to arrest conducted in 2007, before Gant.
The State and Dennis agreed Gant made the search unlawful, but the dispute centered on whether a good-faith exception could save the evidence.
Daniel held that a good-faith exception could apply to pre-Gant searches based on reliance on K.S.A. 22-2501(c).
The Court of Appeals panel declined to apply Daniel, citing lack of explicit statutory reliance and timing distinctions.
The Kansas Supreme Court granted review to determine whether the good-faith exception could apply under the then-existing authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Daniel controls applying a good-faith exception.	State relied on Daniel to permit good-faith relief.	Dennis urged Daniel did not control the outcome.	Daniel controls; good-faith exception applies.
Whether reliance on K.S.A. 22-2501(c) can be inferred from the arrest-search setup.	State argued reliance could be inferred from the search-incident-to-arrest framing.	Dennis asserted no explicit reliance on the statute was shown.	Objective reasonableness suffices; explicit statute recital not required.
Whether pre-Gant case law was sufficiently settled to permit a good-faith exception.	State contends settled pre-Gant authority supported reliance.	Dennis contends the law was unsettled and relied on later cases.	Pre-Gant authorities were sufficiently settled; good-faith exception applies.

Daniel v. State, 291 Kan. 490 (2010) (good-faith exception for pre-Gant searches under K.S.A. 22-2501(c))
Arizona v. Gant, 556 U.S. 332 (2009) (limits warrantless searches incident to arrest of vehicle)
Henning, 289 Kan. 136 (2009) (parallel Fourth Amendment/§15 protection to suppress evidence)
Anderson, 259 Kan. 16 (1996) (statutory scope of search incident to arrest under K.S.A. 22-2501)
Conn, 278 Kan. 387 (2004) (scope of search incident to arrest under statutory framework)
Hoeck, 284 Kan. 441 (2007) (application of good-faith exception prior to Gant)
Davis v. United States, 131 S. Ct. 2419 (2011) (good-faith exception based on reasonable reliance on binding precedent)
Krull, 480 U.S. 340 (1987) (reliance on statute for administrative searches)
Leon, 468 U.S. 897 (1984) (objective reasonableness standard for good-faith exceptions)
Humphrey, 208 F.3d 1190 (10th Cir. 2000) (pre-Gant Tenth Circuit view on search incident to arrest)
McCane, 573 F.3d 1037 (10th Cir. 2009) (pre-Gant Tenth Circuit precedent cited in good-faith analysis)
Vandevelde, 36 Kan. App. 2d 262 (2006) (officer safety scope under pre-2006 statute; not controlling for 22-2501(c))
Thornton v. United States, 541 U.S. 615 (2004) (divisions in the Supreme Court about vehicle searches post-arrest)