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58 A.3d 961
Vt.
2012
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Background

  • Consolidated appeal of Edmonds and Cobb challenging suppression of evidence from DLS stops.
  • Stops followed random registration checks; officers inferred the driver from the registered owner.
  • Edmonds: owner had Vermont license suspended; trooper stopped the car and Edmonds admitted driving.
  • Cobb: owner had license suspended; car moved, trooper approached and Cobb was driver.
  • Trial court denied suppression, treating Fourth Amendment and Article 11 as identical; defendants pled guilty conditioned on appeal.
  • Court affirms that stops were supported by reasonable suspicion under both the Fourth Amendment and Vermont Constitution Article 11.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the stops were supported by reasonable suspicion under the Fourth Amendment and Article 11 Edmonds/Cobb contend no reasonable suspicion since owner’s suspension alone ≠ driver identification State argues owner suspension plus inference driver could reasonably drive the car Yes; stops were supported by reasonable suspicion under both provisions

Key Cases Cited

  • State v. Caron, 155 Vt. 492 (Vt. 1990) (establishes that police may stop with specific, articulable facts and rational inferences of potential wrongdoing)
  • Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes stop standard based on reasonable suspicion, not certainty)
  • United States v. Holland, 510 F.2d 453 (9th Cir. 1975) (illustrates that reasonable suspicion does not require certainty)
  • United States v. Sokolow, 490 U.S. 1 (U.S. 1989) (confirms lower threshold for stop versus probable cause)
  • State v. Simoneau, 2003 VT 83 (Vt. 2003) (defines reasonable and articulable suspicion standard in Vermont)
Read the full case

Case Details

Case Name: State v. Edmonds
Court Name: Supreme Court of Vermont
Date Published: Oct 12, 2012
Citations: 58 A.3d 961; 192 Vt. 400; 2012 VT 81; 2011-426
Docket Number: 2011-426
Court Abbreviation: Vt.
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