fellow officer rule in Washington

2025Mance, 82 Wn.

2013App. 539 , 918 P.2d 527 (1996), to argue that the fellow officer rule applies equally to exculpatory information.

2013State v. Gaddy, 152 Wn.2d 64,70-71 , 93 P.3d 872 (2004) (declining to apply the fellow officer rule to permit an arrest based on information disseminated by a nonpolice agency).

2013State v. Gaddy, 152 Wn.2d 64, 70-71 , 93 P.3d 872 (2004) (declining to apply the fellow officer rule to permit an arrest based on information disseminated by a nonpolice agency). ¶17 The State argues that the fellow officer rule applies to warrantless misdemeanor and gross misdemeanor arrests.

2013State v. Gaddy, 152 Wn.2d 64,70-71 , 93 P.3d 872 (2004) (declining to apply the fellow officer rule to permit an arrest based on information disseminated by a nonpolice agency).

2013State v. Gaddy, 152 Wn.2d 64, 70-71 , 93 P.3d 872 (2004) (declining to apply the fellow officer rule to permit an arrest based on information disseminated by a nonpolice agency). ¶17 The State argues that the fellow officer rule applies to warrantless misdemeanor and gross misdemeanor arrests.

2013Additionally, in his concurring and dissenting opinion to Staats v. Brown, 139 Wn.2d at 791 , Justice Talmadge noted that the fish and wildlife officer was entitled to rely on information provided by a wildlife agent to support his probable cause determination that the defendant had committed a misdemeanor.

2013Additionally, in his concurring and dissenting opinion to Staats, 139 Wn.2d at 791 , Justice Talmadge noted that the fish and wildlife officer was entitled to rely on information provided by a wildlife agent to support his probable cause determination that the defendant had committed a misdemeanor.

2011In response to the dancer's RCW 10.31.100 claim, this court stated, "We have no difficulty applying the fellow officer rule to the facts of this case." Torrey, 76 Wash. App. at 39 , 882 P.2d 799 (citing Maesse, 29 Wash.App. at 647 , 629 P.2d 1349 , and Alvarado, 56 Wash.App. at 456-57 , 783 P.2d 1106 , as examples of Washington's adoption of the fellow officer rule).

2011In response to the dancer's RCW 10.31.100 claim, this court stated, "We have no difficulty applying the fellow officer rule to the facts of this case." Torrey, 76 Wash. App. at 39 , 882 P.2d 799 (citing Maesse, 29 Wash.App. at 647 , 629 P.2d 1349 , and Alvarado, 56 Wash.App. at 456-57 , 783 P.2d 1106 , as examples of Washington's adoption of the fellow officer rule).

2001The State was not required to utilize the fellow-officer rule to establish the factual basis for the stolen vehicle report in Sandholm because its reliability was established by other means, i.e., strong physical evidence that the vehicle had, in fact, been stolen. 96 Wn.

2001The State was not required to utilize the fellow-officer rule to establish the factual basis for the stolen vehicle report in Sandholm because its reliability was established by other means, i.e., strong physical evidence that the vehicle had, in fact, been stolen. 96 Wash.App. at 848 , 980 P.2d 1292 .

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018"The fellow officer rule, also known as the police team rule, allows a court to consider the cumulative knowledge of police officers in determining whether there was probable cause to arrest a suspect."11 The arresting officer has probable cause to arrest a suspect when an officer directing or communicating with him has probable cause, regardless of whether he personally possesses sufficient information to constitute probable cause.12 10 State v. Walker, 157 Wn.2d 307, 310 , 138 P.3d 113 (2006). 11 State v. Bravo Ortega, 177 Wn.2d 116, 126 , 297 P.3d 57 (2013). 12 State v. Maesse, 29 Wn.

2018"The fellow officer rule, also known as the police team rule, allows a court to consider the cumulative knowledge of police officers in determining whether there was probable cause to arrest a suspect."11 The arresting officer has probable cause to arrest a suspect when an officer directing or communicating with him has probable cause, regardless of whether he personally possesses sufficient information to constitute probable cause.12 10 State v. Walker, 157 Wn.2d 307, 310 , 138 P.3d 113 (2006). 11 State v. Bravo Ortega, 177 Wn.2d 116, 126 , 297 P.3d 57 (2013). 12 State v. Maesse, 29 Wn.

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018Ervin, 169 Wn.2d 815, 820 , 239 P.3d 354 (2010). 26 Ervin, 169 Wn.2d at 820 . 27 Ervin, 169 Wn.2d at 820 (quoting State v. Jacobs, 154 Wn.2d 596, 600 , 115 P.3d 281 (2005)). 28 Ervin, 169 Wn.2d at 820 (quoting Ravenscroft v. Wash. Water Power Co., 136 Wn.2d 911, 920-21 , 969 P.2d 75 (1998)). 8 No. 76902-2-1/9 one reasonable interpretation, does a court use statutory construction, legislative history, and relevant case law to help discern legislative intent.29 In Bravo Ortega, our Supreme Court held that the plain language of former RCW 10.31.100 did not permit application of the fellow officer

2018"The fellow officer rule, also known as the police team rule, allows a court to consider the cumulative knowledge of police officers in determining whether there was probable cause to arrest a suspect."11 The arresting officer has probable cause to arrest a suspect when an officer directing or communicating with him has probable cause, regardless of whether he personally possesses sufficient information to constitute probable cause.12 10 State v. Walker, 157 Wn.2d 307, 310 , 138 P.3d 113 (2006). 11 State v. Bravo Ortega, 177 Wn.2d 116, 126 , 297 P.3d 57 (2013). 12 State v. Maesse, 29 Wn.

2018"The fellow officer rule, also known as the police team rule, allows a court to consider the cumulative knowledge of police officers in determining whether there was probable cause to arrest a suspect."11 The arresting officer has probable cause to arrest a suspect when an officer directing or communicating with him has probable cause, regardless of whether he personally possesses sufficient information to constitute probable cause.12 10 State v. Walker, 157 Wn.2d 307, 310 , 138 P.3d 113 (2006). 11 State v. Bravo Ortega, 177 Wn.2d 116, 126 , 297 P.3d 57 (2013). 12 State v. Maesse, 29 Wn.

2018She relies on Nall, 117 Wn.

2018Thus, in the "two separate encounters" scenario, Officer Oates's decision to seize Butler must be justified by information premised solely on his own first- 10 "The United States Supreme Court applied these same principles to a Terry stop in United States v. Hensley, 469 U.S. 221 , 105 S. Ct. 675 , 83 L.

2018Thus, in the "two separate encounters" scenario, Officer Oates's decision to seize Butler must be justified by information premised solely on his own first- 10 "The United States Supreme Court applied these same principles to a Terry stop in United States v. Hensley, 469 U.S. 221 , 105 S. Ct. 675 , 83 L.

2018App. 542, 548-51 , 31 P.3d 733 (2001).10 Here, the State relies on the fellow officer rule to justify Officer Oates's reliance on Officer Allen's knowledge of Butler's actions in order to justify Officer Oates's seizure of Butler.

2011App. 523, 531 , 523 P.2d 1209 (1974) (radio confirmation from police headquarters that the suspect had an outstanding warrant was sufficient to form probable cause); cf. State v. Gaddy, 152 Wn.2d 64, 71 , 93 P.3d 872 (2004) (holding that information obtained from the Department of Licensing may not be subject to the fellow officer rule). ¶13 No published misdemeanor prosecution case has explicitly held that the fellow officer rule applies.

2001Professor LaFave teaches that "when a conclusory allegation (e.g., that a named individual is a drug dealer) is obtained from some computerized compilation of information *740 but no showing is made as to the basis of that allegation, it must be treated as if it were nothing more than an anonymous tip" [citing] United States v. Ornelas-Ledesma, 16 F.3d 714 (7th Cir.1994). 2 Wayne R.