State v. Gates
145 So. 3d 288
| La. | 2014Background
- Gates charged with DWI-3rd offense after initial stop by Officer Bell outside his jurisdiction.
- Defendant moved to suppress evidence obtained after detention, arguing (a) anonymous tip insufficient for detention and (b) lack of permission from jurisdictional agency.
- Trial court suppressed all evidence; appellate court affirmed, applying Williams factors for officers outside jurisdiction.
- Louisiana Supreme Court held the Williams factors are not a mandatory checklist and rejected a per se exclusion for out-of-jurisdiction stops when totality of circumstances show reasonableness.
- Court concluded the stop was constitutionally reasonable; suppressed evidence rule did not bar admissibility; remanded for further proceedings; judgment of lower courts vacated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop constitutionally reasonable given outside-jurisdiction actions? | Gates | Gates | Reasonable under totality of circumstances |
| Did anonymous tip information alone justify initial detention? | State | Gates | Corroborated by officer’s own observations; sufficient reasonable suspicion |
| Did Williams factors constrain the analysis or should totality control? | State | Gates | Williams factors are not mandatory; totality governs |
| Does a territorial-jurisdiction violation warrant suppression of post-detention evidence? | State | Gates | No; exclusion not required for evidence obtained after valid detention |
| Was the detention initiated under Article 213 proper given close pursuit concepts? | State | Gates | Yes; close pursuit permitted initiation outside jurisdiction; action reasonable |
Key Cases Cited
- State v. Williams, 46 So.3d 262 (La. App. 2 Cir. 2010) (appellate factors for officer outside jurisdiction; not a constitutional standard)
- State v. Stapa, 46 So.3d 264 (La. App. 2 Cir. 2010) (companion to Williams; stop by officer outside jurisdiction considered)
- State v. Durke, 885 So.2d 513 (La. 2004) (non-constitutional territorial violation not always suppressive)
- State v. Bickham, 404 So.2d 929 (La. 1981) (territorial jurisdiction and close pursuit; exclusionary remedy limited)
- Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (anonymous tip with indicia of reliability can support reasonable suspicion)
- Elliott v. State, 35 So.3d 247 (La. 2010) (dispatcher's reliability and 911-like information can justify stops)
- Boothe v. State, 844 So.2d 1139 (La. App. 2 Cir. 2003) (distinguishes Boyle and supports reasonableness of observed conduct)
- Boyle v. State, 793 So.2d 1281 (La. App. 2 Cir. 2001) (anonymous tip alone insufficient; later emphasis on observed behavior)