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Kansas v. Glover

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Supreme Court of the United States
Kansas v. Glover
Term: 2019
Important Dates
Argument: November 4, 2019
Decided: Apri 6, 2020
Outcome
Reversed and remanded
Vote
8-1
Majority
Clarence Thomas • Chief Justice John G. Roberts • Stephen Breyer • Samuel Alito • Neil Gorsuch • Brett Kavanaugh
Concurring
Elena Kagan • Ruth Bader Ginsburg
Dissenting
Sonia Sotomayor


Kansas v. Glover is a case argued before the Supreme Court of the United States on November 4, 2019, during the court's October 2019-2020 term. The case came on a writ of certiorari to the Kansas Supreme Court.

The court reversed and remanded the decision of the Kansas Supreme Court in an 8-1 ruling, holding that when an officer lacks information negating an inference that the vehicle's owner is driving the vehicle, an investigative traffic stop made after running a vehicle's license plate and learning that the registered owner's driver's license has been revoked is reasonable under the Fourth Amendment.[1] Click here for more information.


HIGHLIGHTS
  • The case: A Douglas County police officer stopped Charles Glover on suspicion of driving without a valid license. The officer did not witness any traffic violations. Glover was charged with driving as a habitual violator. Glover moved to suppress evidence from the stop, arguing the officer violated Glover's Fourth Amendment rights. The state district court agreed, dismissing the case. On appeal, the Kansas Court of Appeals reversed the district court's ruling. Glover petitioned the Kansas Supreme Court for review. The state supreme court affirmed the district court's ruling, dismissing the case.
  • The issue: Whether, for purposes of an investigative stop under the Fourth Amendment, it is reasonable for an officer to suspect that the registered owner of a vehicle is the one driving the vehicle absent any information to the contrary.
  • The outcome: The court reversed and remanded the Kansas Supreme Court's decision in an 8-1 ruling, holding that when an officer lacks information negating an inference that the vehicle's owner is driving the vehicle, an investigative traffic stop made after running a vehicle's license plate and learning that the registered owner's driver's license has been revoked is reasonable under the Fourth Amendment.[1]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • April 6, 2020: U.S. Supreme Court reversed and remanded the Kansas Supreme Court's ruling.
    • November 4, 2019: Oral argument
    • April 1, 2019: The U.S. Supreme Court agreed to hear the case.
    • October 25, 2018: Kansas filed a petition with the U.S. Supreme Court.
    • July 27, 2018: The Kansas Supreme Court reversed the judgment of the Kansas Court of Appeals and affirmed the judgment of the state district court.

    Background

    While on patrol, Douglas County Sheriff's Deputy Mark Mehrer ran a registration check on a 1995 Chevrolet pickup truck. Mehrer learned Charles Glover, Jr., had registered the truck and his license had been revoked. Mehrer assumed Glover was driving the truck and initiated a traffic stop even though he did not observe any traffic violations. After identifying the truck driver as Glover, the State charged Glover with driving as a habitual violator.[2][3]

    Glover moved to suppress evidence from the stop, arguing Mehrer violated Glover's Fourth Amendment rights against unreasonable searches and seizures. The state district court granted the motion to dismiss. The state filed an appeal, and the Kansas Court of Appeals reversed the district court's decision. Glover petitioned to the Kansas Supreme Court.[2][3]

    The state supreme court rejected the Court of Appeal's decision, affirming the district court's dismissal of the case.[2]

    The State of Kansas petitioned the U.S. Supreme Court for review. In the petition, the state said, "Kansas now asks this Court to grant review to resolve the split the Kansas Supreme Court’s decision creates with the decisions of more than two dozen other courts that have decided the question, including numerous state supreme courts and intermediate state appellate courts, and several federal circuit courts."[4]

    The Fourth Amendment

    See also: Bill of Rights, United States Constitution

    The Fourth Amendment to the United States Constitution provides:

    “ The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.[5] ”

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether, for purposes of an investigative stop under the Fourth Amendment, it is reasonable for an officer to suspect that the registered owner of a vehicle is the one driving the vehicle absent any information to the contrary.[6]

    Outcome

    In an 8-1 ruling, the court reversed and remanded the decision of the Kansas Supreme Court, holding that when an officer lacks information negating an inference that the vehicle's owner is driving the vehicle, an investigative traffic stop made after running a vehicle's license plate and learning that the registered owner's driver's license has been revoked is reasonable under the Fourth Amendment.[1]

    Justice Clarence Thomas delivered the opinion of the court. Justice Elena Kagan filed a concurring opinion, joined by Justice Ruth Bader Ginsburg. Justice Sonia Sotomayor filed a dissenting opinion.[1]

    Opinion

    In his opinion, Justice Clarence Thomas wrote:[1]

    “ This 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. ...


    This Court's precedents have repeatedly affirmed that "the ultimate touchstone of the Fourth Amendment is 'reasonableness'." Heien, 574 U.S., at 60 (quoting Riley v. California, 573 U.S. 373, 381 (2014)). Under the totality of the circumstances of this case, Deputy Mehrer drew an entirely reasonable inference that Glover was driving while his license was revoked.

    We emphasize the narrow scope of our holding. Like all seizures, "[t]he officer's action must be 'justified at its inception.'" Hiibel v. Sixth Judicial Dist. Court of Nev., Humboldt Cty., 542 U.S. 177, 185 (2004) (quoting United States v. Sharpe, 470 U. S. 675, 682 (1985)). "The standard takes into account the totality of the circumstances--the whole picture." Navarette, 572 U.S., at 397 (internal quotation marks omitted). As a result, the presence of additional facts might dispel reasonable suspicion. See Terry, supra, at 28. For example, if an officer knows that the registered owner of the vehicle is in his mid-sixties but observes that the driver is in her mid-twenties, then the totality of the circumstances would not "raise a suspicion that the particular individual being stopped is engaged in wrongdoing." Cortez, 449 U.S. at 418; Ornelas, 517 U.S., at 696 ("'[e]ach case is to be decided on its own facts and circumstances'" (quoting Ker v. California, 374 U.S. 23, 33 (1963)). Here, Deputy Mehrer possessed no exculpatory information--let alone sufficient information to rebut the reasonable inference that Glover was driving his own truck--and thus the stop was justified.[5]

    		”

    Concurring opinion

    Justice Elena Kagan filed a concurring opinion, joined by Justice Ruth Bader Ginsburg.[1]

    In her concurring opinion, Justice Kagan wrote:

    “ In this strange case, contested on a barebones stipulation, the record contains no evidence of these kinds. There is but a single, simple fact: A police officer learned from a state database that a car on the road belonged to a person with a revoked license. Given that revocations in Kansas nearly always stem from serious or repeated driving violations, I agree with the Court about the reasonableness of the officer's inference that the owner, "Glover[,] was driving while his license was revoked." Ante, at 9. And because Glover offered no rebuttal, there the matter stands. But that does not mean cases with more complete records will all wind up in the same place. A defendant like Glover may still be able to show that his case is different—that the "presence of additional facts" and circumstances "dispel[s] reasonable suspicion." Ibid. Which is to say that in more fully litigated cases, the license-revocation alert does not (as it did here) end the inquiry. It is but the first, though no doubt an important, step in assessing the reasonableness of the officer's suspicion.[5] ”

    Dissenting opinion

    Justice Sonia Sotomayor filed a dissenting opinion.[1]

    In her dissent, Justice Sotomayor wrote:[1]

    “ In upholding routine stops of vehicles whose owners have revoked licenses, the Court ignores key foundations of our reasonable-suspicion jurisprudence and impermissibly and unnecessarily reduces the State’s burden of proof. I therefore dissent. ...


    Vehicle stops "interfere with freedom of movement, are inconvenient, and consume time." Prouse, 440 U.S., at 657. Worse still, they "may create substantial anxiety" through an "unsettling show of authority." Ibid. Before subjecting motorists to this type of investigation, the State must possess articulable facts and officer inferences to form suspicion. The State below left unexplained key components of the reasonable-suspicion inquiry. In an effort to uphold the conviction, the Court destroys Fourth Amendment jurisprudence that requires individualized suspicion. I respectfully dissent.[5]

    		”

    Text of the opinion

    Read the full opinion here.

    Audio



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Supreme Court of the United States, Kansas v. Glover, decided April 6, 2020
    2. ↑ 2.0 2.1 2.2 Kansas Supreme Court, State v. Glover, decided July 27, 2018
    3. ↑ 3.0 3.1 Oyez, "Kansas v. Glover," accessed June 7, 2019
    4. ↑ Supreme Court of the United States, "Petition for a writ of certiorari," October 25, 2018
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Questions presented: 18-556 Kansas v. Glover," accessed June 7, 2019
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