State v. Grayson
336 S.W.3d 138
| Mo. | 2011Background
- Officer Lambert received an anonymous tip alleging a drunken driver named Terry Reed with an outstanding parole warrant would be in a red Ford pickup near West Fifth Street.
- Lambert could not locate the Ford but saw a red Mazda pickup with a driver he thought resembled Reed, and began to follow it.
- The stop occurred even though the vehicle did not match the tip and no traffic violations or intoxication signs were observed.
- Upon approaching, Lambert learned the driver was Matthew Grayson, not Reed, and there were no warrants or grounds to detain based on this observation.
- Lambert detained Grayson and checked for warrants, resulting in a municipal warrant arrest; Grayson was placed in a patrol car and transported to jail.
- In jail, Lambert found a small bag of methamphetamine under the patrol car seat, which led to Grayson’s possession charge and the suppression dispute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether initial stop based on anonymous tip violated Fourth Amendment | Grayson | Grayson | Unreasonable; stop unlawful |
| Whether continued detention after identifying Grayson was lawful | Grayson | Grayson | Unreasonable; no articulable suspicion to prolong |
| Whether taint from illegal seizure was attenuated by warrant arrest | Grayson | Grayson | Attenuation not established; taint not purged |
| Whether evidence found in patrol car should be suppressed as fruit of the illegal seizure | Grayson | Grayson | Suppressed |
| Whether independent source or inevitable discovery doctrines apply | Grayson | Grayson | Do not apply |
Key Cases Cited
- Deck v. State, 994 S.W.2d 527 (Mo. banc 1999) (corroboration required for anonymous tips; Deck held sufficient corroboration when independent indicia exist)
- Miller v. State, 894 S.W.2d 649 (Mo. banc 1995) (anonymous tip alone insufficient; corroboration required)
- Franklin v. State, 841 S.W.2d 639 (Mo. banc 1992) (dispatch alone cannot establish reasonable suspicion)
- Terry v. Ohio, 392 U.S. 1 (1968) (limits on stop and frisk to reasonable suspicion)
- Brown v. Illinois, 422 U.S. 590 (1975) (attenuation factors for taint from illegality)
- Nix v. Williams, 467 U.S. 431 (1984) (attenuation/inevitable discovery framework; taint considerations)
- Hudson v. Michigan, 547 U.S. 586 (2006) (knock-and-announce context; not controlling on attenuation)