Collective Knowledge Doctrine; Traffic Stop; Prolonged Detention
LE stopped a vehicle that was suspected of involvement in drug trafficking pursuant to two anonymous tipsters. These sources had similar information. When the vehicle was observed, much of the information given was found to be true (the tipsters predicted accurately future behavior of the subject). At the time of the stop, LE radioed for a PSD unit to respond. As LE was filling out the citation, the PSD team arrived 26 minutes after the stop. PSD alerted to the vehicle. Subject complained that the PSD alert prolonged the detention impermissibly.
The court held that LE had additional reasonable suspicion to investigate drug crimes at the time of the stop. Basically, the court held that there was enough detail in the two tips to show a sufficient reliability of the information to provide reasonable suspicion to investigate possible drug crimes. In addition, the officer making the stop was allowed to use the collective knowledge that this vehicle had been seen recently making frequent and brief stops at a known drugs house.