McReynolds v. State

3 Citing cases

  1. State v. Spillner

    116 Haw. 351 (Haw. 2007)   Cited 34 times
    Holding that one-week-old insurance information, and two-week-old license information, was not stale and provided reasonable suspicion to validly pull over the vehicle

    Conversely, where the information relied upon by the officer was so "stale" that, when considered in light of the length of the license suspension or the ease in obtaining the proper credentials, the logical link between the former illegal activity and any suspicion of current, ongoing criminal activity had dissolved with the passage of time, courts have concluded that investigatory stops were unreasonable. See, e.g., McReynolds v. State, 441 So.2d 1016, 1017-19 (Ala.Crim.App. 1983) (one year stale); Moody v. State, 842 So.2d 754, 758 (Fla. 2003) (noting that `Vhen, as in this case, as many as three years pass without any further information about a person's driving status, and, when, as in this case, that person's license can be restored through a simple administrative process, the staleness of the officer's information is indeed an important factor," and ruling the stop unreasonable); Boyd v. State, 758 So.2d 1032, 1036 (Miss.Ct.App. 2000) (reasoning that because eight years had passed since the officer last knew that the defendant's license was suspended and the officer did not know the length of the suspension, the stop was not supported by reasonable suspicion); Commonwealth v. Stevenson, 832 A.2d 1123, 1125, 1130-32 n. 9 (Pa.Super.Ct. 2003) (holding that, where the officer did not know the length of the defendant's license suspension and in light of the three-year interval between the officer's last knowledge of the defendant's license status and the pres

  2. Sawyer v. City of Marion

    666 So. 2d 113 (Ala. Crim. App. 1995)   Cited 1 times

    Specifically, he contends that Carter's belief that the appellant's driving privileges had been suspended did not rise to the level of a reasonable suspicion to believe he was violating the law, as required by Terry. The appellant bases his contention primarily on the United States Supreme Court's holding in Delaware v. Prouse, 440 U.S. 648, 99 S.Ct. 1391, 59 L.Ed.2d 660 (1979), and this court's holding in McReynolds v. State, 441 So.2d 1016 (Ala.Cr.App. 1983). In Prouse, a police officer stopped a motorist at random to see if he had a driver's license.

  3. Duckworth v. State

    612 So. 2d 1284 (Ala. Crim. App. 1993)   Cited 6 times
    In Duckworth, this Court held it was unreasonable for an officer to stop a car late at night in an high crime area simply because the vehicle "looked out of place."

    There was no indication that Officer Bishop and Officer Podstata were working together so that the knowledge of one officer may be imputed to the other for purposes of determining "probable cause" to stop. McReynolds v. State, 441 So.2d 1016 (Ala.Cr.App. 1983). Therefore, the validity of the stop rests on whether Officer Bishop, who made the stop without any assistance from or contact with Officer Podstata, had a "reasonable suspicion" that a crime had been or was about to be committed. Knight v. State, 346 So.2d 478 (Ala.Cr.App. 1977).