Magnuson v. Comm'r of Pub. Safety, 703 N.W.2d 557, 559-60 (Minn.App. 2005) ("Under the doctrine of collective knowledge, the factual basis justifying the investigatory stop need not be known to the officer acting in the field."); see also Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984) ("The factual basis for stopping a vehicle may arise from information supplied by someone other than the arresting officer."). When the factual basis supporting a stop is supplied by another person, "the information must be reliable and credible."
An officer may rely on information from another officer under the "collective knowledge" principle, which imputes the entire knowledge of the police force to all officers. Magnuson v. Comm'r of Pub. Safety, 703 N.W.2d 557, 559 (Minn.App. 2005) ("Under the doctrine of collective knowledge, the factual basis justifying the investigatory stop need not be known to the officer acting in the field."); see also Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984) ("The factual basis for stopping a vehicle may arise from information supplied by someone other than the arresting officer."
A district court does not err by failing to address an issue not raised in the petition for judicial review. Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn. App. 1984) At the implied-consent hearing, appellant informed the district court that he waived all issues but his challenge to the constitutionality of the implied-consent statute, reasonable articulable suspicion for the stop, and probable cause for the test. Because appellant did not argue the vindication of counsel issue to the district court, he has waived review of it on appeal. Thiele v. Stick, 425 N.W.2d 580, 582 (Minn.
The specific-pleading requirement alerts the commissioner and the district court to the specific matters at issue; the district court does not err by failing to address an issue not raised in the petition for judicial review. Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn. App. 1984). Because Thompson did not raise the constitutionality of the implied-consent statute below, it is waived on appeal.
The purpose of the specific-pleadings requirement is to alert the commissioner and the district court to the specific matters at issue. Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn. App. 1984). A district court does not err by failing to address an issue not raised in the petition for judicial review.
Rather, information possessed by several officers may be aggregated to determine whether the stop was justified. Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984). Although the officer "must have a particularized and objective basis for suspecting the particular person stopped of criminal activity," law enforcement officials are permitted to make deductions that "might well elude an untrained person."
The purpose of the specific-pleadings requirement is to alert the commissioner and the district court to the specific matters at issue. Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984). A district court does not err by failing to address an issue not raised in the petition for judicial review and not raised at the hearing.
Marben v. State, Dep't of Pub. Safety, 294 N.W.2d 697, 699 (Minn. 1980); see Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984) (holding that radio messages regarding defendant's erratic driving, combined with arresting officer's independent observation, was sufficient cause for investigatory stop). Thoe argues that Deputy Dyshawe stopped him based on a "mere hunch" that Thoe was fleeing a domestic assault.
Olson v. Comm'r of Pub. Safety, 371 N.W.2d 552, 555 (Minn. 1985); accord Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984); see also State v. Riley, 568 N.W.2d 518, 523 (Minn. 1997) (stating Minnesota uses "collective knowledge" approach to determine whether probable cause existed when more than one officer is involved in investigation).
Revocation of driving privileges under Minnesota's implied-consent statute is subject to both administrative review, Minn. Stat. ยง 169A.53, subd. 1 (2002), and judicial review, id., subd. 2 (2002). The two proceedings are separate and unrelated. Rancour v. Comm'r of Pub. Safety, 355 N.W.2d 462, 464 (Minn.App. 1984). Coleman sought administrative review of his 1999 revocation, but he did not seek judicial review.