W.D.Mo.: Misreading a “hot sheet” for stop of a car was objectively reasonable mistake

Police had a “hot sheet,” a list of stolen cars from a car dealership, and were on the look out. “In this case, Officer Palmer believed that the red Dodge Challenger had been stolen from the dealership in Excelsior Springs, Missouri. This belief was based on his review of hot sheets that morning which listed stolen automobiles in the Kansas City area. Although this belief was supported by a misreading of the hot sheets, I find this mistake to be objectively reasonable.” The mistake was one letter difference in reading the sheets. United States v. Williams, 2017 U.S. Dist. LEXIS 186059 (W.D. Mo. Aug. 7, 2017).*

The search of the car here was supported by consent. If not consent, inevitable discovery applies because inventory was next. United States v. Marin, 2017 U.S. Dist. LEXIS 184005 (D. Md. Nov. 7, 2017).*

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