Kansas v. Glover

589 U.S. 376, 140 S. Ct. 1183, 206 L. Ed. 2d 412
Supreme Court of the United States·Decided April 6, 2020·No. No. 18-556·Published·Cited by 260 cases

Opinions

Justice THOMAS delivered the opinion of the Court.

*1186This case presents the question whether a police officer violates 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. We hold that when the officer lacks information negating an inference that the owner is the driver of the vehicle, the stop is reasonable.

I

Kansas charged respondent Charles Glover, Jr., with driving as a habitual violator after a traffic stop revealed that he was driving with a revoked license. See *1187Kan. Stat. Ann. § 8-285(a)(3) (2001). Glover filed a motion to suppress all evidence seized during the stop, claiming that the officer lacked reasonable suspicion. Neither Glover nor the police officer testified at the suppression hearing. Instead, the parties stipulated to the following facts:

"1. Deputy Mark Mehrer is a certified law enforcement officer employed by the Douglas County Kansas Sheriff 's Office.
2. On April 28, 2016, Deputy Mehrer was on routine patrol in Douglas County when he observed a 1995 Chevrolet 1500 pickup truck with Kansas plate 295ATJ.
3. Deputy Mehrer ran Kansas plate 295ATJ through the Kansas Department of Revenue's file service. The registration came back to a 1995 Chevrolet 1500 pickup truck.
4. Kansas Department of Revenue files indicated the truck was registered to Charles Glover Jr. The files also indicated that Mr. Glover had a revoked driver's license in the State of Kansas.
5. Deputy Mehrer assumed the registered owner of the truck was also the driver, Charles Glover Jr.
6. Deputy Mehrer did not observe any traffic infractions, and did not attempt to identify the driver [of] the truck. Based solely on the information that the registered owner of the truck was revoked, Deputy Mehrer initiated a traffic stop.
7. The driver of the truck was identified as the defendant, Charles Glover Jr." App. to Pet. for Cert. 60-61.

The District Court granted Glover's motion to suppress. The Court of Appeals reversed, holding that "it was reasonable for [Deputy] Mehrer to infer that the driver was the owner of the vehicle" because "there were specific and articulable facts from which the officer's common-sense inference gave rise to a reasonable suspicion." 54 Kan.App.2d 377, 385, 400 P.3d 182, 188 (2017).

The Kansas Supreme Court reversed. According to the court, Deputy Mehrer did not have reasonable suspicion because his inference that Glover was behind the wheel amounted to "only a hunch" that Glover was engaging in criminal activity. 308 Kan. 590, 591, 422 P.3d 64, 66 (2018). The court further explained that Deputy Mehrer's "hunch" involved "applying and stacking unstated assumptions that are unreasonable without further factual basis," namely, that "the registered owner was likely the primary driver of the vehicle" and that "the owner will likely disregard the suspension or revocation order and continue to drive." Id., at 595-597, 422 P.3d at 68-70. We granted Kansas' petition for a writ of certiorari, 587 U. S. ----, 139 S.Ct. 1445, 203 L.Ed.2d 680 (2019), and now reverse.

II

Under this Court's precedents, the Fourth Amendment permits an officer to initiate a brief investigative traffic stop when he has "a particularized and objective basis for suspecting the particular person stopped of criminal activity." United States v. Cortez , 449 U.S. 411, 417-418, 101 S.Ct. 690, 66 L.Ed.2d 621 (1981) ; see also Terry v. Ohio , 392 U.S. 1, 21-22, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968). "Although a mere 'hunch' does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause." Prado Navarette v. California , 572 U.S. 393, 397, 134 S.Ct. 1683, 188 L.Ed.2d 680 (2014) (quotation altered); United States v. Sokolow , 490 U.S. 1, 7, 109 S.Ct. 1581, 104 L.Ed.2d 1 (1989).

*1188Because it is a "less demanding" standard, "reasonable suspicion can be established with information that is different in quantity or content than that required to establish probable cause." Alabama v. White , 496 U.S. 325, 330, 110 S.Ct.

Free access — add to your briefcase to read the full text and ask questions with AI

Kansas v. Glover, 589 U.S. 376, 140 S. Ct. 1183, 206 L. Ed. 2d 412 (2020).

589 U.S. 376 (Kansas v. Glover) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

United States v. Raban
Tenth Circuit, 2025
People of Michigan v. Dustin Ross Anderson
Michigan Court of Appeals, 2025
Commonwealth v. Luis Morales
Massachusetts Appeals Court, 2025
United States v. Abass
District of Columbia, 2025
Shuler v. State
Court of Special Appeals of Maryland, 2025
State v. Schwartz
Court of Appeals of Kansas, 2025
Commonwealth v. Castillo-Martinez
Massachusetts Appeals Court, 2024
James Douglas Webb v. Commonwealth of Virginia
Court of Appeals of Virginia, 2024
A V v. State of Indiana
Indiana Court of Appeals, 2024
Com. v. Hutchinson, R.
Superior Court of Pennsylvania, 2023
Com. v. Hadlock, C.
Superior Court of Pennsylvania, 2023
Commonwealth v. Jackson, K., Aplt.
Supreme Court of Pennsylvania, 2023
United States v. Hagood
78 F.4th 570 (Second Circuit, 2023)
People v. Williams
2023 IL App (4th) 220481-U (Appellate Court of Illinois, 2023)
Reginald C. Gilbert v. the State of Texas
Court of Appeals of Texas, 2023
In re A.C. CA5
California Court of Appeal, 2023