State v. Knox
2016 ND 15
| N.D. | 2016Background
- Deputy Per Perez was dispatched to M&M Trailer Park on Zoe Road after State Radio relayed a report that a blue Toyota pickup and a gray Jeep Cherokee were driving around selling drugs; the reporting party said the occupants attempted to sell him drugs.
- Perez arrived about four to five minutes after dispatch, observed a gray Jeep Cherokee, stopped the vehicle driven by Dustin Knox, and arrested him when he discovered Knox’s license was suspended.
- A search of the vehicle produced methamphetamine and drug paraphernalia; Knox was charged with possession of a controlled substance and possession of paraphernalia (driving under suspension charge later dismissed).
- Knox moved to suppress, arguing the stop lacked reasonable suspicion and relied on an anonymous, uncorroborated tip; the district court denied the motion.
- Knox conditionally pled guilty, reserving the right to appeal the suppression denial; the Supreme Court reviewed whether the district court’s findings adequately explained its denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officer had reasonable suspicion to stop the vehicle | The stop was supported because the anonymous tip identified vehicle type and location, which Perez corroborated | The tip was an anonymous, bare assertion that occupants were selling drugs and lacked corroboration of criminal activity | Reversed: district court’s findings insufficient to permit review of whether reasonable suspicion existed |
| Whether the tip was anonymous or identifiable and the effect on reliability | State treated the tip as anonymous but argued sufficient corroboration of vehicle and location made it reliable | Knox argued the tip was effectively anonymous and of low reliability requiring more corroboration | Court noted record evidence suggested the reporting party’s identity was ascertainable and that the district court failed to make findings on reliability |
| Whether Navarette v. California applies (911 tip reliability factors) | State did not rely on Navarette at trial; district court did not consider it | Knox argued the tip lacked indicia of reliability like eyewitness basis or 911 safeguards | Court instructed the district court to consider Navarette on remand and make findings applying its factors |
| Whether the district court provided adequate findings of fact and legal reasoning | State argued the court’s brief reliance was sufficient | Knox argued the court’s order gave no factual or legal explanation for denying suppression | Held that the district court’s order lacked adequate factual findings and legal analysis, preventing meaningful appellate review; remanded for detailed findings (additional evidence permitted) |
Key Cases Cited
- Navarette v. California, 134 S. Ct. 1683 (2014) (911 tip can supply reasonable suspicion when it shows eyewitness basis, timeliness, and 911’s reliability safeguards)
- State v. Miller, 510 N.W.2d 638 (N.D. 1994) (tip reliability assessed by quantity-quality tradeoff under totality of circumstances)
- City of Dickinson v. Hewson, 803 N.W.2d 814 (N.D. 2011) (informant reliability relevant to reasonable-suspicion analysis)
- State v. Juntunen, 845 N.W.2d 325 (N.D. 2014) (trial court must make adequate findings explaining its decision)
- Anderson v. Director, N.D. Dep’t of Transp., 696 N.W.2d 918 (N.D. 2005) (informant whose identity is easily ascertainable has higher indicia of reliability)