United States v. Katrina Lyons
2012 U.S. App. LEXIS 15300
| 6th Cir. | 2012Background
- DEA investigated QRMP for prescription drug and Medicare fraud; Stratford Road house used as medical office and hub for trafficking.
- Surveillance on Sept. 25, 2008 linked the Stratford Road site to QRMP’s operations and identified a gray minivan with Alabama plates as involved.
- DEA relayed a short, filtered briefing to Michigan Troopers to stop the minivan if feasible, while preserving DEA's investigative details.
- Troopers stopped the minivan for a vision-obstruction civil infraction and then secured consent to search, discovering over $11,000, multiple cough syrups, and other items.
- District court granted suppression, concluding the stop was invalid and not based on DEA information; the government appealed.
- Court reverses and remands, holding the stop was valid under the collective knowledge doctrine and the search permissible under the automobile exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the DEA had reasonable suspicion to order the stop. | Lyons: stop premised on pretext and no collective knowledge. | Lyons: stop unsupported by reasonable suspicion on DEA info. | Yes; stop supported by reasonable suspicion and collective knowledge. |
| Whether the troopers properly acted on the DEA's collective knowledge. | Lyons: shared information insufficient for stop. | DEA’s information imputable to troopers; improper to dissect. | Yes; collective knowledge doctrine applied; stop valid. |
| Whether the vehicle search was permissible under the automobile exception and whether consent was voluntary. | Search justified by probable cause; consent uncontested. | Consent disputed; district court did not decide. | Automobile exception satisfied; probable cause supported; consent issue not resolved on record. |
Key Cases Cited
- United States v. Arvizu, 534 F.3d 266 (U.S. Supreme Court, 2002) (reasonable suspicion analyzed under totality of the circumstances)
- Illinois v. Wardlow, 528 U.S. 119 (U.S. Supreme Court, 2000) (presence in high-crime area may contribute to suspicion; corroborating factors needed)
- Whren v. United States, 517 U.S. 806 (U.S. Supreme Court, 1996) (pretext not forbidden per se if stop based on probable cause)
- United States v. Hensley, 469 U.S. 221 (U.S. Supreme Court, 1985) (collective knowledge doctrine permitted in some interagency stops)
- Whiteley v. Warden, 401 U.S. 560 (U.S. Supreme Court, 1971) (collective knowledge justified by multiple-agency communication)
- United States v. Blair, 524 F.3d 740 (U.S. 6th Cir., 2008) (limits of collective knowledge where information not conveyed prior to stop)
- United States v. Smith, 510 F.3d 641 (6th Cir., 2007) (DEA’s broader investigation can justify probable cause to search vehicle)