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Database Error Still Reasonable Suspicion for a Stop

Authorities must have reasonable suspicion of criminal activity before they can lawfully seize a person to conduct an investigation. Stopping a motor vehicle by a show of authority is a seizure. But though the suspicion must be reasonable, that does not necessarily mean it must be accurate. In the recent Tennessee case of State v. Meadows, M2013-01650-CCA-R3-CD (Tenn.Crim.App. 2-10-2015), the Court of Criminal Appeals found that a vehicle stop which was based on incorrect information in a database was still reasonable, as it was reasonable for the police officer to rely on that information.

In the Meadows case, a Metro Nashville police officer was patrolling an area where, in his experience, it was not uncommon to see older model vehicles displaying registration tags which were registered to another vehicle. The officer often used a laptop to check the status of vehicle tags on vehicles he observed in the area. According to the officer, the database information indicated the Defendant's tag on his pickup truck was assigned to a different vehicle.

Upon stopping the Defendant's vehicle, the Defendant was able to produce a valid registration indicating his truck actually did have the correct license tag. However, the officer also discovered the Defendant had no drivers' license and was a habitual motor offender.

After the trial court denied the Defendant's motion to suppress evidence from the stop, the Defendant pled guilty and reserved a certified question of law for appeal, challenging whether there was reasonable suspicion for the stop, given that the information upon which was the stop was based was incorrect.

The Court of Criminal Appeals agreed with the trial court reasoning that even though the database may have contained an error, it was reasonable for the police officer to rely upon the information in the database, absent some evidence of widespread errors within the database rendering it generally unreliable.

This is also consistent with other Court of Criminal Appeals opinions addressing similar circumstances.

For more information on what facts may constitute reasonable suspicion for an investigatory stop, contact Hindman & Associates.

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