State v. Holdorf
333 P.3d 982
Or.2014Background
- Defendant was passenger in blue SUV driven by Watts, a known felon under investigation for meth distribution; Officer Davis alerted Salang about Watts and the vehicle and Watts’ warrant status.
- Salang stopped the SUV after Watts committed a traffic infraction; backup officers arrived; Watts was removed and defendant remained seated.
- Salang observed defendant appear nervous, fidgety, avoid eye contact, and look “tweaking,” which he attributed to methamphetamine use based on training and experience.
- Salang conducted a patdown after a knife was observed in defendant’s possession; a second knife and three small containers with marijuana and methamphetamine were later found.
- Defendant moved to suppress the evidence arguing the stop was unsupported by reasonable suspicion; trial court denied; Court of Appeals reversed; Oregon Supreme Court reversed the Court of Appeals and affirmed the circuit court.
- The Court held that Salang could rely on information shared by other officers under the collective knowledge doctrine and that Salang’s observation of defendant’s behavior, combined with his training and the corroborating information about Watts, established reasonable suspicion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Salang may rely on information from other officers to establish reasonable suspicion | Salang's stop was justified by collective knowledge | Salang could not rely on secondhand information to justify the stop | Yes, permissible under collective knowledge doctrine |
| Whether Salang’s observation of methamphetamine influence, based on training and other relied-upon facts, established reasonable suspicion | Observation plus training supported reasonable suspicion | Observation alone or training insufficient without corroborating facts | Yes, the stop was supported by reasonable suspicion |
Key Cases Cited
- State v. Valdez, 277 Or 621 (1977) (objective test for reasonable suspicion under ORS 131.615; high-threshold for intuitive hunches)
- State v. Lichty, 313 Or 579 (1992) (informant information supplemented by officer’s expertise to infer criminal activity)
- State v. Ehly, 317 Or 66 (1993) (totality-of-circumstances; officer experience used to justify stop)
- State v. Kennedy, 290 Or 493 (1981) (integration of ORS 131.605–131.625 with constitutional standards)
- State v. Soldahl, 331 Or 420 (2000) (collective knowledge doctrine applies to arrests; extends to stops based on shared information)