State v. Washington, 943 N.W.2d 757

Officer stopped Washington for speeding; Washington produced a Michigan driver's license and said it had recently been reinstated and state records might be out of date.
Officer could not confirm status through his dispatcher, then contacted a second law-enforcement source which reported Washington’s driving privileges were suspended.
Officer returned and attempted to arrest Washington for driving with a suspended license; Washington fled, was apprehended, and charged with, among other counts, fleeing and preventing arrest.
Washington moved to suppress evidence, arguing the arrest was illegal because his Michigan license was valid; the district court denied the motion and advised validity of arrest could be a trial defense.
Washington entered conditional guilty pleas preserving appellate review of the suppression ruling; the court of appeals reviewed de novo legal questions and deferred to factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arrest was unlawful and suppression required because Washington had a valid license	Officer lawfully relied on information indicating suspension; arrest justified	Washington contends his license was valid, so arrest was unlawful and evidence should be suppressed	Court affirmed: factual findings supported officer’s understanding that license was suspended and, even if license was valid, officer acted in objectively reasonable good faith reliance so suppression was not appropriate

State v. Vigen, 927 N.W.2d 430 (N.D. 2019) (standard of review for suppression motions; deference to district court factual findings)
State v. Marcum, 939 N.W.2d 840 (N.D. 2020) (exclusion of evidence not proper when police act in good-faith, objectively reasonable reliance)
State v. Barth, 637 N.W.2d 369 (N.D. 2001) (officer acted in good faith executing warrantless arrest after radio confirmation of suspended license)