collective knowledge doctrine in Ohio

2021Montgomery No. 23926, 2011-Ohio-1984, ¶ 20 (the collective knowledge doctrine “permits police officers to rely on information provided to them by other officers in helping to establish probable cause or reasonable suspicion”).

2018Montgomery No. 23926, 2011-Ohio-1984, ¶ 20 (the collective knowledge doctrine “permits police officers to rely on information provided to them by other officers in helping to establish probable cause or reasonable suspicion”).

2023“This ‘typically requires [a showing] that the officer making the stop [or arrest] was [personally] aware of sufficient facts to justify it[.]’ ” State v. Pickett, 2017-Ohio-5830 , 94 N.E.3d 1046, ¶ 9 (2d Dist.), quoting City of Maumee v. Weisner, 87 Ohio St.3d 295, 297 , 720 N.E.2d 507 (1999). {¶ 24} The collective knowledge doctrine, however, “permits police officers to rely on information provided to them by other officers in helping to establish probable cause or reasonable suspicion.” (Citations omitted.) State v. Jones, 2d Dist.

2023“This ‘typically requires [a showing] that the officer making the stop [or arrest] was [personally] aware of sufficient facts to justify it[.]’ ” State v. Pickett, 2017-Ohio-5830 , 94 N.E.3d 1046, ¶ 9 (2d Dist.), quoting City of Maumee v. Weisner, 87 Ohio St.3d 295, 297 , 720 N.E.2d 507 (1999). {¶ 24} The collective knowledge doctrine, however, “permits police officers to rely on information provided to them by other officers in helping to establish probable cause or reasonable suspicion.” (Citations omitted.) State v. Jones, 2d Dist.

2023“This ‘typically requires [a showing] that the officer making the stop [or arrest] was [personally] aware of sufficient facts to justify it[.]’ ” State v. Pickett, 2017-Ohio-5830 , 94 N.E.3d 1046, ¶ 9 (2d Dist.), quoting City of Maumee v. Weisner, 87 Ohio St.3d 295, 297 , 720 N.E.2d 507 (1999). {¶ 24} The collective knowledge doctrine, however, “permits police officers to rely on information provided to them by other officers in helping to establish probable cause or reasonable suspicion.” (Citations omitted.) State v. Jones, 2d Dist.

2022Wayne No. 20AP0030, 2021-Ohio-3700, ¶ 8 , quoting State v. Mays, 119 Ohio St.3d 406 , 2008-Ohio-4539 , ¶ 7 Typically, to justify an investigative stop, an officer must point to “‘specific and articulable facts which, taken together with rational inferences from those facts, 6 reasonably warrant that intrusion.’” Maumee v. Weisner, 87 Ohio St.3d 295, 299 (1999), quoting Terry v. Ohio, 392 U.S. 1, 21 (1968). {¶15} The collective knowledge doctrine, however, recognizes that “[a] police officer need not always have knowledge of the specific facts justifying a stop and may rely, therefore, upon a p

2024“Under such circumstances, the State must show that the officer who provided the information had a valid reasonable suspicion of criminal activity or sufficient facts adding up to probable cause.” (Citations omitted.) State v. Hammer, 2023-Ohio-1307 , 213 N.E.3d 238, ¶ 23 (2d Dist.). {¶ 48} Although the State now relies upon the collective knowledge doctrine to justify the warrantless detention of Harrell, it is dubious whether the evidence adduced at the hearing on the motion to suppress supported the application of the collective knowledge doctrine to the facts of this case.

2024“Under such circumstances, the State must show that the officer who provided the information had a valid reasonable suspicion of criminal activity or sufficient facts adding up to probable cause.” (Citations omitted.) State v. Hammer, 2023-Ohio-1307 , 213 N.E.3d 238, ¶ 23 (2d Dist.). {¶ 48} Although the State now relies upon the collective knowledge doctrine to justify the warrantless detention of Harrell, it is dubious whether the evidence adduced at the hearing on the motion to suppress supported the application of the collective knowledge doctrine to the facts of this case.

2022Wayne No. 20AP0030, 2021-Ohio-3700, ¶ 8 , quoting State v. Mays, 119 Ohio St.3d 406 , 2008-Ohio-4539 , ¶ 7 Typically, to justify an investigative stop, an officer must point to “‘specific and articulable facts which, taken together with rational inferences from those facts, 6 reasonably warrant that intrusion.’” Maumee v. Weisner, 87 Ohio St.3d 295, 299 (1999), quoting Terry v. Ohio, 392 U.S. 1, 21 (1968). {¶15} The collective knowledge doctrine, however, recognizes that “[a] police officer need not always have knowledge of the specific facts justifying a stop and may rely, therefore, upon a p

2017This court explained the doctrine as follows: The collective knowledge doctrine recognizes that "[a] police officer need not always have knowledge of the specific facts justifying a stop and may rely, therefore, upon a police dispatch or flyer." Maumee v. Weisner , 87 Ohio St.3d 295 , 297, 1999-Ohio-68 , 720 N.E.2d 507 (1999), citing United States v. Hensley , 469 U.S. 221 , 231, 105 S.Ct. 675 , 83 L.Ed. 2d 604 (1985). "[T]he admissibility of the evidence uncovered during such a stop does not rest upon whether the officers relying upon a dispatch or flyer 'were themselves aware of the specific

2025Pursuant to the collective knowledge doctrine, “knowledge of law enforcement officers is imputed to other officers.’” State v. Muldrow, 2016-Ohio- 4774, ¶ 18 (10th Dist.); State v. Brown, 2007-Ohio-464, ¶ 34 (11th Dist.) (“it is the collective knowledge of the law-enforcement officers that allows the arresting officer to rely upon those facts to effect an arrest”).

2025We disagree. {¶ 24} “Though nothing would prohibit the state from calling every officer who was involved in relaying or receiving the information, the critical inquiry for a court in considering a motion to suppress based on the collective knowledge doctrine is whether the facts precipitating the dispatch supported a finding of reasonable suspicion.” State v. Muldrow, 2016-Ohio-4774 , ¶ 21 (10th Dist.), citing State v. Taylor, 2006-Ohio-5866, ¶ 7 (10th Dist.).

2023Montgomery No. 28857, 2022-Ohio-551, ¶ 24 , citing United States v. Horne, 4 F.3d 579, 585 (8th Cir.1993) (“[P]robable cause may be based on the collective knowledge of all law enforcement officers involved in an investigation and need not be based solely upon the information within the knowledge of the officer on scene[.]”).” This collective-knowledge doctrine permits officers to form probable cause (or reasonable suspicion) based upon information that another law enforcement officer provided.

2023See, e.g., State v. Wortham, 145 Ohio App.3d 126, 130 , 761 N.E.2d 1151 (2nd Dist.2001); United States v. Beck, 765 F.2d 146 (6th Cir.1985) (the collective-knowledge doctrine typically applied in determining probable cause to arrest “is equally applicable to a search warrant”); accord United States v. Spears, 965 F.2d 262, 277 (7th Cir.1992) (“In determining whether probable cause exists, a magistrate is entitled to regard an affiant’s fellow law enforcement officers as reliable sources.”).

2023See, e.g., State v. Wortham, 145 Ohio App.3d 126, 130 , 761 N.E.2d 1151 (2nd Dist.2001); United States v. Beck, 765 F.2d 146 (6th Cir.1985) (the collective-knowledge doctrine typically applied in determining probable cause to arrest “is equally applicable to a search warrant”); accord United States v. Spears, 965 F.2d 262, 277 (7th Cir.1992) (“In determining whether probable cause exists, a magistrate is entitled to regard an affiant’s fellow law enforcement officers as reliable sources.”).

2023See, e.g., State v. Wortham, 145 Ohio App.3d 126, 130 , 761 N.E.2d 1151 (2nd Dist.2001); United States v. Beck, 765 F.2d 146 (6th Cir.1985) (the collective-knowledge doctrine typically applied in determining probable cause to arrest “is equally applicable to a search warrant”); accord United States v. Spears, 965 F.2d 262, 277 (7th Cir.1992) (“In determining whether probable cause exists, a magistrate is entitled to regard an affiant’s fellow law enforcement officers as reliable sources.”).

2023See, e.g., State v. Wortham, 145 Ohio App.3d 126, 130 , 761 N.E.2d 1151 (2nd Dist.2001); United States v. Beck, 765 F.2d 146 (6th Cir.1985) (the collective-knowledge doctrine typically applied in determining probable cause to arrest “is equally applicable to a search warrant”); accord United States v. Spears, 965 F.2d 262, 277 (7th Cir.1992) (“In determining whether probable cause exists, a magistrate is entitled to regard an affiant’s fellow law enforcement officers as reliable sources.”).

2022Wayne No. 20AP0030, 2021-Ohio-3700, ¶ 8 , quoting State v. Mays, 119 Ohio St.3d 406 , 2008-Ohio-4539 , ¶ 7 Typically, to justify an investigative stop, an officer must point to “‘specific and articulable facts which, taken together with rational inferences from those facts, 6 reasonably warrant that intrusion.’” Maumee v. Weisner, 87 Ohio St.3d 295, 299 (1999), quoting Terry v. Ohio, 392 U.S. 1, 21 (1968). {¶15} The collective knowledge doctrine, however, recognizes that “[a] police officer need not always have knowledge of the specific facts justifying a stop and may rely, therefore, upon a p

2016United States v. Williams, 627 F.3d 247 , 252–53 (7th Cir.2010) (citing United States v. Nafzger, 974 F.2d 906, 911 (7th Cir.1992)).

2011See, e.g., State v. Harris (July 24, 1981), Lucas App. No. L-81-018, quoting United States v. Ventresca (1965), 380 U.S. 102, 111 , 85 S.Ct. 741 , 13 L.Ed.2d 684 (“observations of fellow officers of the Government engaged in a common investigation are plainly a reliable basis for a warrant applied for by one of their number.”); United States v. Beck (6th Cir. 1985), 765 F.2d 146 (the collective knowledge doctrine typically applied in determining probable cause to arrest “is equally applicable to a search warrant”).

2011See, e.g., State v. Harris (July 24, 1981), Lucas App. No. L-81-018, quoting United States v. Ventresca (1965), 380 U.S. 102, 111 , 85 S.Ct. 741 , 13 L.Ed.2d 684 (“observations of fellow officers of the Government engaged in a common investigation are plainly a reliable basis for a warrant applied for by one of their number.”); United States v. Beck (6th Cir. 1985), 765 F.2d 146 (the collective knowledge doctrine typically applied in determining probable cause to arrest “is equally applicable to a search warrant”).