Kansas v. Glover

Supreme Court of the United States · 2020 · Criminal Procedure
589 U.S. 376 (2020)
Updated
Criminal ProcedureFourth AmendmentInvestigative traffic stopsReasonable suspicionTerry stoptraffic stopregistered owner inferencerevoked license

Facts

A Douglas County deputy observed a 1995 Chevrolet pickup truck and ran its Kansas license plate through the state database. The database showed the truck was registered to Charles Glover, Jr., and that Glover's Kansas driver's license had been revoked. The deputy did not observe any traffic infractions and did not attempt to identify the driver before stopping the truck. He stopped the truck based solely on the assumption that the registered owner was the driver, and the driver was in fact Glover.

Issue

Whether the Fourth Amendment permits an officer to initiate an investigative traffic stop after running a vehicle's license plate and learning that the registered owner has a revoked driver's license, when the officer has no information negating the inference that the owner is driving.

Rule

Under the Fourth Amendment, an officer may initiate a brief investigative traffic stop when the officer has a particularized and objective basis for suspecting the person stopped of criminal activity. When an officer learns that a vehicle's registered owner has a revoked driver's license and lacks information negating the inference that the owner is driving, the commonsense inference that the owner is likely the driver provides reasonable suspicion for the stop.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
While on patrol in Tulsa, Officer Nina Patel runs the plate of a blue sedan. The database shows the plate matches that sedan, the car is registered to Owen Mercer, and Mercer’s Oklahoma driver’s license is revoked. Officer Patel sees no traffic violation and cannot make out the driver before stopping the car.

Did Officer Patel have reasonable suspicion to make the stop?

Explanation. Yes. The majority held that when an officer learns a vehicle’s registered owner has a revoked license and lacks information negating the inference that the owner is driving, the officer has reasonable suspicion for an investigative traffic stop. The standard is less demanding than probable cause and permits commonsense inferences about human behavior; no observed traffic infraction or specialized training is required.