Kansas v. Glover

When an officer runs a license plate and learns that the owner has a revoked license—absent knowledge of any contradictory facts—it is reasonable for the officer to infer that the driver is also the owner of the vehicle, and the traffic stop is justified.

Respondent was charged as a “habitual violator” for driving with a revoked license. Respondent claimed that the officer failed to meet the reasonable suspicion standard required to make a traffic stop and filed a motion to suppress all of the resultant evidence. The district court granted Respondent’s motion. The court of appeals reversed, holding that the officer’s common-sense inference that the driver was the owner of the vehicle was reasonable and “gave rise to a reasonable suspicion.” The state supreme court reversed, stating that the officer’s inference was merely a “hunch.” On appeal, the United States Supreme Court reversed, holding that when an officer lacks any facts contradicting the inference that the owner of the vehicle is the one driving, a traffic stop for driving with a revoked license is reasonable. The Supreme Court reasoned that Fourth Amendment precedent recognizes that an officer’s common-sense inference can be drawn from everyday experiences, rather than solely from law enforcement training. Furthermore, the Supreme Court reasoned that, under a “totality of the circumstances” analysis, the officer had “individualized suspicion” that Respondent was engaged in a criminal act based on database information regarding the vehicle’s description and the owner’s revoked license, empirical knowledge that drivers with revoked licenses often continue to drive, and the officer's own common-sense inference that the driver was the registered owner of the vehicle. Therefore, the traffic stop was justified. REVERSED and REMANDED.