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  • Law School Case Brief

Kansas v. Glover - 140 S. Ct. 1183 (2020)

Rule:

Regarding whether a police officer violates the Fourth Amendment by initiating an investigative traffic stop after running a vehicles license plate and learning that the registered owner has a revoked drivers license, the United States Supreme Court holds that when an officer lacks information negating an inference that the owner is the driver of the vehicle, the stop is reasonable.

Facts:

A Kansas deputy sheriff ran a license plate check on a pickup truck, discovering that the truck belonged to respondent Glover and that Glover's driver's license had been revoked. The deputy pulled the truck over because he assumed that Glover was driving. Glover was in fact driving and was charged with driving as a habitual violator. He moved to suppress all evidence from the stop, claiming that the deputy lacked reasonable suspicion. The District Court granted the motion, but the Court of Appeals reversed. The Kansas Supreme Court in turn reversed, holding that the deputy violated the Fourth Amendment by stopping Glover without reasonable suspicion of criminal activity.

Issue:

Did the deputy sheriff violate the Fourth Amendment by initiating an investigative traffic stop after running a vehicle's license plate and learning that the registered owner has a revoked driver's license?

Answer:

No

Conclusion:

The Court held that when an officer lacks information negating an inference that the owner is the driver of the vehicle, the stop is reasonable. The facts known to a deputy sheriff at the time of the stop gave rise to a reasonable suspicion. Before initiating the stop, the deputy observed an individual operating a pickup truck with a Kansas license plate. The deputy also knew that the registered owner of the truck had a revoked license and that the model of the truck matched the observed vehicle. The deputy drew the commonsense inference that Glover was likely the driver of the vehicle, which provided more than reasonable suspicion to initiate the stop.

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