United States v. Gregory J. Edwards
885 F.2d 377, 1989 U.S. App. LEXIS 14208, 1989 WL 107888 (1989)
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Rule of Law:
Under the collective knowledge doctrine, probable cause for a warrantless arrest can be established based on the totality of information known to a team of officers conducting an investigation, even if the arresting officers do not personally possess all the facts, as long as there is some degree of communication between them.
Facts:
- A confidential informant, MPD 917, told Detective David Mahoney that a man named 'Greg' would sell cocaine to Steven Kreger at the East Towne Mall.
- The informant stated the transaction would occur around 7:00 p.m. and Kreger would be driving a red 1977 Camaro.
- Detective Mahoney, along with Detectives Richard Pharo and Allen Rickey, set up surveillance at the mall.
- A Chevrolet Blazer, driven by Gregory Edwards, parked next to Kreger's Camaro. Detective Mahoney observed a man standing between the two vehicles before getting into the Blazer, but saw no exchange.
- After the vehicles left in opposite directions, Mahoney ran the Blazer's plates and found it was registered to Gregory Edwards, but his attempt to radio this information to the other officers was hampered by a malfunctioning radio system.
- Detectives Pharo and Rickey followed the Blazer, having not received the registration information. Only Detective Rickey heard Mahoney's radio transmission that 'the meet had taken place.'
- Detectives Pharo and Rickey blocked Edwards' Blazer in a restaurant parking lot, drew their weapons, and ordered Edwards and his passenger out of the vehicle.
Procedural Posture:
- Gregory Edwards filed several pretrial motions to suppress evidence in the United States District Court.
- A magistrate judge reviewed the motions and recommended that they all be denied.
- The district court judge adopted the magistrate's recommendation, denying Edwards's motions to suppress.
- Pursuant to a negotiated plea agreement, Edwards pleaded guilty to one count of possession of cocaine with intent to distribute, while reserving his right to appeal the denial of his suppression motions.
- Edwards (appellant) appealed the district court's adverse rulings to the United States Court of Appeals for the Seventh Circuit.
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Issue:
Does the collective knowledge of a team of law enforcement officers establish probable cause for a warrantless arrest under the Fourth Amendment when some key facts known by one officer were not successfully communicated to the arresting officers?
Opinions:
Majority - Harlington Wood, Jr.
Yes, the collective knowledge of the officers established probable cause. The court held that under the collective or 'imputed' knowledge doctrine, the knowledge of all officers working together on a scene and in communication can be aggregated to determine probable cause. While Detective Mahoney's specific knowledge that the Blazer was registered to a 'Greg' could not be imputed because it was not communicated, his radio transmission that 'the meet had taken place' was received by Detective Rickey. This communication, combined with the other officers' knowledge of the informant's tip and their own observations, was sufficient. The knowledge of Detective Rickey (who heard the transmission) could be imputed to Detective Pharo because they were acting as a team. Therefore, the team as a whole possessed sufficient information to constitute a 'probability or substantial chance of criminal activity,' meeting the standard for probable cause and rendering the warrantless arrest lawful.
Analysis:
This decision reinforces the practical application of the collective knowledge doctrine in multi-officer investigations, allowing courts to assess probable cause by looking at the total information known to the police team. It clarifies an important limitation: knowledge cannot be imputed from one officer to another if there is no evidence it was communicated. The ruling provides law enforcement with operational flexibility but also requires at least some communication among officers for the doctrine to apply, preventing agencies from justifying arrests with uncommunicated information held by a single officer.
