State v. Johnson
354 S.W.3d 627
| Mo. | 2011Background
- Consolidated appeals involve legality of vehicle searches incident to traffic arrests; four arrestees were handcuffed or secured when searches occurred; searches were conducted under binding prior precedents (Belton/ Harvey) before Gant overruled them; Missouri Constitution Article I, §15 protections align with the Fourth Amendment; Davis held reasonable reliance on binding precedent can excuse suppression; some defendants’ motions to suppress were granted while others were denied in the trial courts; the appellate court must decide on the exclusionary rule’s applicability post-overruling precedent; Johnson’s arrest had probable cause and the evidence in his vehicle was seized incident to a valid arrest; Keith/Dustin/IHeather case details are used to frame the issue of standing and the scope of search; the court ultimately affirms Johnson, but reverses Kingsley and Hicks suppression orders and remands those cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence from searches incident to arrest must be suppressed when based on binding precedent later overturned | State relies on Davis: objectively reasonable reliance forecloses suppression | Defendants rely on Gant/Belton: searches were unlawful | No suppression due to objective reasonable reliance |
| Whether Davis's objective-reliance standard applies to all defendants including Johnson | State: Davis applies to all cases | Defendants: applicable to the specific factual scenario | Applicable; exclusionary rule does not apply |
| Whether subjective good faith is required to avoid suppression under Davis | State: not required; objective standard governs | Defendants: Davis discussion of culpability implies subjective test | Subjective good faith not required; objective standard governs |
Key Cases Cited
- New York v. Belton, 453 U.S. 454 (U.S. 1981) (bright-line rule permitting search of passenger compartment during arrest)
- State v. Harvey, 648 S.W.2d 87 (Mo. banc 1983) (Mo. adoption of Belton interpretation prior to Gant)
- Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (overruled Belton-based framework for searches after arrestee is secured)
- Davis v. United States, 131 S. Ct. 2419 (2011) (objectively reasonable reliance on binding precedent defeats exclusionary rule; retroactivity discussion separate)
- State v. Oliver, 293 S.W.3d 437 (Mo. banc 2009) (state constitution protections coextensive with Fourth Amendment)
- State v. Gaw, 285 S.W.3d 318 (Mo. banc 2009) (standard for suppression rulings; de novo review of legal questions)