State v. Johnson
2011 SD 10
S.D.2011Background
- Johnson was convicted of first degree robbery for a Sioux Falls casino holdup.
- Emergency dispatch notified police of the robbery; witnesses said the suspect fled on foot east and carried a handgun.
- Officer Trainor, responding to the dispatch, positioned to observe traffic north of 37th Street and stopped the only northbound vehicle within moments of the robbery, which carried Johnson as a passenger.
- A search of the vehicle yielded a bag of money and a pellet gun; Johnson moved to suppress the stop and evidence.
- The trial court denied suppression, ruling the stop was supported by reasonable suspicion; it later noted a nonfunctioning brake light could have justified the stop but did not observe it at the time.
- On appeal, Johnson challenges only the initial traffic stop’s validity; the supreme court affirms, holding the stop was supported by reasonable suspicion based on totality of the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was based on reasonable suspicion | Johnson contends the stop lacked articulable facts. | Johnson argues no reasonable suspicion existed at the time. | Stop supported by reasonable suspicion |
Key Cases Cited
- State v. Satter, 2009 S.D. 35 (S.D. 2009) (establishes minimal factual basis for a stop and totality of circumstances)
- Brown v. Texas, 443 U.S. 47 (U.S. Supreme Court 1979) (requires evaluation of specific facts beyond mere location)
- Faulks, 2001 S.D. 115 (S.D. 2001) (upholds stop without precise suspect description when described facts support suspicion)
- State v. Boardman, 264 N.W.2d 503 (S.D. 1978) (intermediate response in pursuit of a burglary suspect on a likely escape route)
- Adams v. Williams, 407 U.S. 143 (U.S. Supreme Court 1972) (recognizes brief stop may be reasonable to obtain information)
- Orvizu v. United States, 534 U.S. 266 (U.S. Supreme Court 2002) (totality of circumstances standard for reasonable suspicion)
- State v. Herren, 2010 S.D. 101 (S.D. 2010) (emphasizes evaluating facts known to officer at time of stop)
- State v. Chavez, 2003 S.D. 93 (S.D. 2003) (discusses limits of intrusions and reliance on observed facts)
- Krebs, 504 N.W.2d 580 (S.D. 1993) (vehicle stop implicated by Fourth Amendment; seizure doctrine)
- State v. Quartier, 2008 S.D. 62 (S.D. 2008) (reasonable suspicion de novo with deference to officer inferences)