Facts: Petitioner Juliet Gaddy was charged with possession of a controlled substance after a search of her car performed by police incident to arresting her for driving with a suspended driver’s license revealed cocaine. During her trial, Gaddy sought to have all evidence obtained from the search suppressed, alleging that the mobile data terminal used to ascertain that her driver’s license was suspended by the officers who had initially stopped her for failing to signal while making a turn was insufficiently reliable to provide probable cause for the arrest and search that followed (as she alleged that her driver’s license was in fact valid). The trial court rejected Gaddy’s motion to suppress and she was convicted. After the Washington Court of Appeals upheld Gaddy’s conviction, she appealed to the Supreme Court of Washington.
Question(s): Did the information obtained from the mobile data terminal provide the officers who stopped Gaddy a sufficiently reasonable basis for believing she had committed the crime of driving with a suspended driver’s license?
Conclusion: Chief Justice Alexander’s opinion for a unanimous Court ruled that the actual status of Gaddy’s driver’s license was irrelevant and that the statutes and regulations in place to ensure that the information provided by the Department of Licensing through its mobile data terminals is accurate gave the information a presumption of reliability that justified the subsequent arrest and search of Gaddy’s car. The Court held that although the Department of Licensing is not a police agency and therefore information provided by it is not entitled to the same presumption of reliability as information provided to the police by fellow officers, such information should be accorded the same status as information provided by a citizen informant.
Petitioner: Juliet Gaddy
(Counsel: Neil M. Fox, Michael P. Iaria, and Alfoster Garrett, Jr.)
Respondent: State of Washington
(Counsel: Norm Maleng and Daniel J. Clark)
Argument: Thursday, March 11, 2004 9:00am
[Source: TVW, http://tvw.org]
Audio: Washington Supreme Court
Decided: Thursday, July 8th, 2004
Prevailing Party: State of Washington (Respondent)
Opinion: 152 Wn.2d 64 (2004)
Court: Alexander2 Court (2003-2004)
Note: We post only slip opinion(s) as published at the time of the decision. Please consult Washington Reports printed volumes for the opinion(s) in their final form.