State v. GloverAnnotate this Case
The Supreme Court held that a law enforcement officer lacked an articulable and reasonable suspicion that the unidentified driver of a car stopped at a traffic stop did not have a valid driver’s license, and therefore, the district court properly granted Defendant’s motion to suppress evidence obtained during the stop.
The officer in this case stopped the car because he assumed the driver was the registered owner, whose driver’s license had been revoked. Defendant, the driver, filed a motion to suppress, arguing that the officer lacked a reasonable suspicion of illegal activity when he stopped the car. The district court denied the motion. The court of appeals reversed, holding that reasonable suspicion can arise because an officer may presume the owner is the driver absent contrary information. The Supreme Court reversed, holding that the court of appeals’ owner-is-the-driver presumption is invalid because it implicitly requires applying and stacking unstated assumptions that are unreasonable without further factual basis and relieves the State of its burden of proving that the officer had particular and individualized suspicion that the registered owner was driving the vehicle.