State v. Johnson

Citations: 354 S.W.3d 627; 2011 WL 6096470Docket: Nos. SC 91173, SC 91182, SC 91214, SC 91429

Court: Supreme Court of Missouri; December 5, 2011; Missouri; State Supreme Court

SummaryOriginalCytator Case TreatmentAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Four consolidated appeals address the admissibility of evidence obtained from searches of motor vehicles incident to traffic arrests. Each defendant was secured at the time of the search, and there was no indication that evidence related to their arrests was present in their vehicles. The searches complied with existing appellate precedent, specifically New York v. Belton and State v. Harvey. However, the Supreme Court's ruling in Arizona v. Gant subsequently deemed such searches unlawful under similar circumstances. Each defendant filed motions to suppress evidence based on Gant, raising the question of whether the exclusionary rule applies to evidence obtained under binding precedent that was later overturned.

The Court references Davis v. U.S., where it was held that a search incident to arrest was a Fourth Amendment violation under similar conditions, but the exclusionary rule did not apply because the officer acted in “objectively reasonable reliance” on the prevailing law. The Missouri Constitution parallels the Fourth Amendment in protecting against unreasonable searches and seizures. Consequently, the Court concludes that searches conducted in reasonable reliance on binding precedent are not subject to the exclusionary rule when that precedent is later overturned.

The judgment denying the motion to suppress in Howard Johnson’s case is affirmed, while the judgments that upheld the motions to suppress in the cases of Dustin Kingsley, Heather Kingsley, and Andrea Hicks are reversed and remanded. In Johnson's case, he was arrested for driving without a valid license, and a subsequent search of his vehicle revealed various drugs and paraphernalia, leading to charges against him. His motion to suppress the evidence was overruled, and the evidence was ultimately admitted at trial.

Johnson was convicted of operating a motor vehicle without a valid license and possession of a controlled substance. Hicks was arrested for driving on a suspended license; during her arrest, an officer searched her vehicle, finding a syringe with methamphetamine. She successfully filed a motion to suppress the evidence, with the court citing State v. Gant as the basis for its decision. Similarly, Dustin Kingsley was stopped for driving with a revoked license, and during his arrest, another officer searched the vehicle, discovering drug paraphernalia. Both Dustin and Heather Kingsley filed motions to suppress the evidence obtained from this search, which the trial court also sustained based on Gant.

The standard of review for a motion to suppress requires substantial evidence supporting the trial court's ruling, favoring the facts and reasonable inferences that support that ruling while disregarding contrary evidence. The legality of the searches and the applicability of the exclusionary rule are legal questions reviewed de novo. Missouri constitutional protections against unreasonable searches are interpreted to be coextensive with those in the Fourth Amendment of the U.S. Constitution.

The legal framework for searches incident to arrest was established in New York v. Belton, allowing warrantless searches of a vehicle's passenger compartment during an arrest. However, Gant later refined this rule, rejecting the notion that officer safety justified a search when the arrestee was secured in a police vehicle, thus limiting the scope of such searches.

Police may search a vehicle incident to a recent occupant's arrest only if the arrestee is within reaching distance of the passenger compartment or if there is a reasonable belief that the vehicle contains evidence related to the offense. Without these justifications, such searches are deemed unreasonable unless a warrant is obtained or another exception to the warrant requirement is established. This ruling, articulated in Gant, overturns the previous interpretation of Belton endorsed in Harvey, which allowed searches regardless of the arrestee's proximity to the vehicle. Following Gant, officers cannot search a vehicle's passenger compartment if the arrestee is secured and out of reach.

The Supreme Court's decision in Davis v. United States clarified that Gant applies retroactively, but the admissibility of evidence from a vehicle search hinges on the exclusionary rule, which is distinct from retroactivity concerns. In Davis, the Court determined that none of the justifications for applying the exclusionary rule were present, as the officers acted in accordance with binding Eleventh Circuit precedent that permitted such searches under the interpretation of Belton. The ruling emphasized that the exclusionary rule is intended to deter police misconduct that is sufficiently egregious, and since the officers acted in good faith reliance on established law, the exclusionary rule was deemed inapplicable. Therefore, in the cases at hand, the officers were also acting in "objectively reasonable reliance" on binding precedent, leading to the conclusion that the exclusionary rule should not apply.

Subjective analysis of an officer's conduct is deemed irrelevant under the precedent set by *Davis*. Johnson argues that the searching officer lacked subjective good faith in his case, contradicting *Davis*, which does not require a subjective good faith showing. The *Davis* standard focuses on whether an officer's actions were based on "objectively reasonable reliance" on binding appellate precedent. Johnson conceded that the arresting officer relied on *Belton* and its progeny during the search incident to arrest. 

While *Davis* noted that the officers involved did not deliberately or recklessly violate Fourth Amendment rights, this does not establish a subjective standard. Instead, *Davis* emphasizes that officers acting in accordance with binding precedent cannot be deemed to have acted wrongfully, thus rendering the exclusionary rule inapplicable. The *Davis* decision clarifies that police conduct, when based on an objectively reasonable belief in its lawfulness, does not warrant the application of the exclusionary rule.

In Johnson's case, the arresting officer had probable cause based on a computer check indicating no valid license, along with Johnson's admission of violating permit terms. Consequently, the search of Johnson's vehicle was justified and in line with *Belton* and *Harvey*. The court concluded that the officers acted in "objectively reasonable reliance" on established precedent, leading to the reversal of trial court judgments in other cases and affirming the judgment in Johnson’s case. The court maintains jurisdiction under the Missouri Constitution.

Heather Kingsley was not secured during the search, which was incident to Dustin Kingsley's arrest, making her arrest irrelevant to the search-incident-to-arrest analysis. The State contended that Heather lacked standing to contest the search's constitutionality, but it did not object to her standing at the suppression hearing, thus failing to preserve the issue for appeal. The search was justified under the principles established in Chimel v. California, which allows searches for officer safety and evidence preservation, and further clarified by Belton, which permits searches of a vehicle's passenger compartment incident to arrest. Relevant case law, including State v. Scott and State v. Reed, supports that searches can occur even if the arrestee is handcuffed and not in immediate access to the vehicle.

There was a factual dispute regarding whether Johnson had a valid Texas driver’s license at the time of his arrest; however, this was deemed irrelevant to the validity of the arrest itself. Probable cause exists when a reasonable officer believes a crime has been committed based on available facts, as upheld in State v. Chapman. The officer had probable cause to arrest Johnson for driving without a valid driver’s license. Heather Kingsley also argued that the searching officer's failure to cite Belton during testimony undermined the "objectively reasonable reliance" standard established in Davis, but this argument lacked merit as the Davis test is objective and does not consider the officer's subjective intent.

Johnson challenged the sufficiency of evidence for his conviction of possession of a controlled substance, but the standard of review confirmed sufficient evidence existed for a reasonable juror to convict. He also questioned the jury instruction related to his conviction for driving without a valid license, admitting he did not preserve the objection, which limited the review to plain error. To prove plain error, he needed to show that the instruction affected the verdict, but he failed to demonstrate entitlement to relief.