CA6: GFE applies to warrantless detention based on state DMV computer response

The good faith exception applies to this warrantless detention which resulted from a regular state computer request which flagged to “verify insurance.” United States v. Warren, 2021 U.S. App. LEXIS 37674 (6th Cir. Dec. 20, 2021):

As framed by the parties, the dispute in this appeal reduces down to the question of whether insurance information in the AVIS database is reliable enough to establish reasonable suspicion. Narrowing their focus to that question, Warren and the government stipulated to a set of agreed-to facts about the traffic stop initiated by the sheriff’s deputy. We hesitate to adopt and apply the putative rule advanced by the government on the basis of the limited factual record available here. Nevertheless, we conclude that, even if the stopping officer did not have reasonable suspicion to initiate the traffic stop, Warren is not entitled to have evidence from the traffic stop excluded from the government’s case against him.

… The stipulated factual record contains no indication that the stopping officer engaged in such troubling conduct. Reviewing the record in the light most favorable to the government, the officer who stopped Warren reasonably acted in good faith that the stop was lawful based on the Kentucky judiciary’s assessment of the AVIS database in Willoughby and Lynem. See Davis, 564 U.S. at 238-39; see also United States v. White, 874 F.3d 490, 497 (6th Cir. 2017). The good-faith exception to the exclusionary rule applies here if the stop was conducted in violation of the Fourth Amendment.