308 P.3d 24
Kan. Ct. App.2013Background
- On Nov. 2, 2011 Trooper Nicholas Wright had closed I-35 for an accident and directed personnel to block the entrance ramp and divert traffic.
- Trooper Wright saw a single private vehicle (driven by Heather Miller) enter the closed section and stopped her, believing she had driven around officers/cones in violation of K.S.A. 8-1503.
- Lenexa officers had briefly left their ramp post for another incident; they did not communicate that to Wright before he stopped Miller.
- After the stop Wright developed reasonable suspicion Miller was intoxicated; field tests and an evidentiary breath test (.122) led to her arrest.
- The district court suppressed the DUI evidence, finding the stop improper because Miller had not in fact disobeyed officers; the State appealed.
- The Court of Appeals reversed, holding Wright’s reasonable, good-faith mistake of fact supplied reasonable suspicion and suppression was improper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a stop based on a factual mistake can provide reasonable suspicion | Miller: Stop unlawful because she did nothing wrong — officers had left, so no infraction occurred | State: Officer’s reasonable factual belief at the time justified the stop | Held: A reasonable, good-faith mistake of fact can support reasonable suspicion; stop was lawful |
| Distinction between mistake of fact and mistake of law | Miller: n/a (argues no violation occurred) | State: Officer wasn’t mistaken about the law — only the facts | Held: Mistake of law defeats suspicion; mistake of fact does not if reasonable and in good faith |
| Whether facts known to other officers impute knowledge to Trooper Wright (collective-knowledge) | Miller: Fellow-officer rule imputes knowledge that roadblock was unattended; stop invalid | State: No communication to Wright, so no imputation | Held: Collective-knowledge doctrine inapplicable because there was no transmission of information to Wright |
| Whether suppression of post-stop evidence was required | Miller: Evidence should be suppressed because stop lacked legal basis | State: Evidence admissible because stop was supported by reasonable suspicion | Held: Evidence should not have been suppressed; case remanded for further proceedings |
Key Cases Cited
- State v. Sanchez-Loredo, 294 Kan. 50 (discussing standard of appellate review of suppression rulings)
- State v. Coleman, 292 Kan. 813 (reasonable-suspicion standard for traffic stops)
- State v. Marx, 289 Kan. 657 (reasonable-suspicion principles)
- Houston v. Clark County Sheriff Deputy John Does, 174 F.3d 809 (officer’s reasonable factual mistake can support suspicion)
- United States v. Ornelas-Ledesma, 16 F.3d 714 (reasonable reliance on perceived facts supports investigatory stops)
- United States v. Bailey, 417 F.3d 873 (reasonable factual mistakes and suspicion analysis)
- United States v. Shareef, 100 F.3d 1491 (Tenth Circuit on reasonable-suspicion analysis)
- Martin v. Kansas Dept. of Revenue, 285 Kan. 625 (mistake of law negates reasonable suspicion)
- State v. Knight, 33 Kan. App. 2d 325 (officer’s legal error invalidated stop)
- State v. Niblock, 230 Kan. 156 (collective-knowledge / fellow-officer rule applies when information is communicated)
- United States v. Williams, 627 F.3d 247 (three-part test for applying collective-knowledge doctrine)
- United States v. Lyons, 687 F.3d 754 (limitations on collective-knowledge application)
- United States v. Massenburg, 654 F.3d 480 (collective-knowledge requires transmission of information)