Category Archives: Collective knowledge

VI: BOLO information shared at beginning of shift satisfies collective knowledge

BOLO information shared with officers at the beginning of their shift qualifies as collective knowledge. Emanuel v. People, 2018 V.I. Supreme LEXIS 10 (June 15, 2018) (relying on United States v. Braden, 2012 U.S. Dist. LEXIS 115755 (W.D. Tenn. July … Continue reading

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PA: Second officer arriving at scene knew enough for collective knowledge to apply; full (and unnecessary) discussion of vertical v. horizontal collective knowledge if you’re interested

Pennsylvania adheres to the vertical approach of collective knowledge. Here, another officer got involved and made the decision to arrest, but he knew what the first officer knew, and that was enough. This was still collective knowledge. (There is a … Continue reading

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M.D.La.: Finding CP image hash values on a computer is PC for search

The finding of child pornography hash values on a computer is probable cause for further search of the computer. United States v. Sherlock, 2018 U.S. Dist. LEXIS 1321 (M.D. La. Jan. 4, 2018).* Playpen warrant sustained, and there was no … Continue reading

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CA11: RS can be found by collective knowledge

Probable cause to search defendant’s vehicle existed based on officers’ collective knowledge, including a tip from an informant who had recently been found with cocaine, identified defendant as his primary supplier, and described how she hid cocaine under her car’s … Continue reading

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PA: Collective knowledge and RS doesn’t require the officer with knowledge actually communicate it to the others

Collective knowledge and reasonable suspicion doesn’t require the officer with knowledge actually communicate it to the others. “It is entirely permissible for an officer to engage in the investigation of a suspect based on the observations of another officer even … Continue reading

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OH10: Stopping the first person officers see after hearing gunshots was without RS

Officers heard gunshots and stopped the first person they saw. That essentially was a stop on a hunch and without reasonable suspicion. State v. Hairston, 2017-Ohio-7612, 2017 Ohio App. LEXIS 3934 (10th Dist. Sept. 14, 2017). “Here, the team of … Continue reading

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C.D.Cal.: Under collective knowledge doctrine, the officer making the stop doesn’t need to know the PC

There was probable cause from collective knowledge for defendant’s stop and the search of his vehicle for a hidden compartment with drugs, even though the stopping officer didn’t know what it was. United States v. Isshpunani, 2017 U.S. Dist. LEXIS … Continue reading

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M.D.Ala.: A “Car-Mart” advertisement in place of the license plate was RS for a stop to inquire whether vehicle just purchased or not

“Thus, having viewed the ‘Car-Mart’ advertisement serving as Defendant’s license tag or plate, Cpl. Williams possessed reasonable suspicion to believe that Defendant was in violation of those laws” about getting a car licensed within 20 days of purchase, so the … Continue reading

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CA4: Even if consent invalid, PC for SW came from independent sources

“[T]he district court did not err in denying Hernandez’s motion to suppress the evidence obtained from the Samsung T199 phone because the search pursuant to the warrant was ‘genuinely independent’ of the initial search. Murray, 487 U.S. at 542.” United … Continue reading

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CA10: Collective knowledge applies between state officers in different states

Kansas officers asked Nebraska officers to stop defendant, and the probable cause of the Kansas officers is imputed to Nebraska officers under the collective knowledge doctrine. United States v. Pickel, 2017 U.S. App. LEXIS 12858 (10th Cir. July 18, 2017). … Continue reading

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CA5: Collective knowledge from narcs applies to justification for traffic stop

The totality of the circumstances did not dictate a finding that a turn-signal violation was too stale to justify stopping defendant’s vehicle. A lack of personalized suspicion on the part of the officer who stopped defendant’s vehicle was immaterial because … Continue reading

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D.Colo.: Collective knowledge doctrine does not require that the officer requesting a stop actually tell the other officers the reason why

The collective knowledge doctrine does not require that the officer requesting a stop actually tell the other officers the reason why. United States v. Rubio-Sepulveda, 2017 U.S. Dist. LEXIS 23866 (D. Colo. Feb. 21, 2017):

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