collective knowledge doctrine (Wisconsin) · Go Syfert
← Wisconsin issues

collective knowledge doctrine in Wisconsin

15 Wisconsin opinions name it 2 courts 2000–2025 6 in the last five years

The cases below were cited by Wisconsin courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
State v. Mabragreen
wis · 1974 · cited in 4 Wisconsin opinions naming this issue, 2000–2022
2 sentences

2022See State v. Mabra, 61 Wis. 2d 613, 625 , 213 N.W.2d 545 (1974); State v. Pickens, 2010 WI App 5, ¶11 , 323 Wis. 2d 226 , 779 N.W.2d 1 (2009). 18 No. 2020AP7-CR ¶39 In their supplemental briefing, the parties disagree as to whether the collective knowledge doctrine applied to provide Stroik with probable cause to arrest Gajewski.

2022See State v. Mabra, 61 Wis. 2d 613, 625 , 213 N.W.2d 545 (1974); State v. Pickens, 2010 WI App 5, ¶11 , 323 Wis. 2d 226 , 779 N.W.2d 1 (2009). 18 No. 2020AP7-CR ¶39 In their supplemental briefing, the parties disagree as to whether the collective knowledge doctrine applied to provide Stroik with probable cause to arrest Gajewski.

24
State v. Alexandergreen
wisctapp · 2005 · cited in 4 Wisconsin opinions naming this issue, 2009–2025
2 sentences

2025Cf. State v. Alexander, 2005 WI App 231, ¶13 , 287 Wis. 2d 645 , 706 N.W.2d 191 (“Under the collective knowledge doctrine, there are situations in which the information in the hands of an entire police department may be imputed to officers on the scene to help establish reasonable suspicion or probable cause.” (citation omitted)). 11 No. 2023AP543-CR ¶29 Given this evidence, we conclude that the circuit court properly refused to suppress Nero’s blood test results.10 “Probable cause is a flexible, commonsense standard” that “requires only that the facts available to the officer would warrant a

2025Cf. State v. Alexander, 2005 WI App 231, ¶13 , 287 Wis. 2d 645 , 706 N.W.2d 191 (“Under the collective knowledge doctrine, there are situations in which the information in the hands of an entire police department may be imputed to officers on the scene to help establish reasonable suspicion or probable cause.” (citation omitted)). 11 No. 2023AP543-CR ¶29 Given this evidence, we conclude that the circuit court properly refused to suppress Nero’s blood test results.10 “Probable cause is a flexible, commonsense standard” that “requires only that the facts available to the officer would warrant a

14
State v. Pickensgreen
wisctapp · 2009 · cited in 4 Wisconsin opinions naming this issue, 2018–2022
2 sentences

2022In addition to its concession that possible suicidal ideation by Bourgeois plays no role in our exigent circumstances analysis, the State also makes no attempt to invoke the collective knowledge doctrine, see State v. Pickens, 2010 WI App 5, ¶13 , 323 Wis. 2d 226 , 779 N.W.2d 1 (2009) (“[I]n a collective knowledge situation, if a defendant moves to suppress, the prosecutor must prove the collective knowledge that supports the stop.”), which in certain circumstances would allow a court considering a suppression motion to combine the knowledge of multiple officers, see State v. Alexander, 2005 W

2022In addition to its concession that possible suicidal ideation by Bourgeois plays no role in our exigent circumstances analysis, the State also makes no attempt to invoke the collective knowledge doctrine, see State v. Pickens, 2010 WI App 5, ¶13 , 323 Wis. 2d 226 , 779 N.W.2d 1 (2009) (“[I]n a collective knowledge situation, if a defendant moves to suppress, the prosecutor must prove the collective knowledge that supports the stop.”), which in certain circumstances would allow a court considering a suppression motion to combine the knowledge of multiple officers, see State v. Alexander, 2005 W

14
State v. Pettitgreen
wisctapp · 1992 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
1 sentence

2024See Pettit, 171 Wis. 2d at 647 .

11
State v. Blackgreen
wisctapp · 2000 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018See Mabra , 61 Wis. 2d at 625 ; State v. Pickens , 2010 WI App 5 , ¶11, 323 Wis. 2d 226 , 779 N.W.2d 1 . ¶27 Burrows argues, based on State v. Black , 2000 WI App 175 , 238 Wis. 2d 203 , 617 N.W.2d 210 , that Manitowoc County was not aware of the details related to probable cause so his arrest was invalid.

2018We noted that in order for the doctrine to apply, "such information must actually be passed to the officer before he or she makes an arrest or conducts a search." Id. , ¶17 n.4; see also State v. Friday , 140 Wis. 2d 701 , 712, 412 N.W.2d 540 (Ct. App. 1987), rev'd on other grounds , State v. Friday , 147 Wis. 2d 359 , 434 N.W.2d 85 (1989) (citation omitted) (noting that "[i]n addition to examining the totality of the circumstances" we must also consider "the degree of communication between" the police officers, rather than the "sole knowledge" of one officer). ¶28 We disagree that the collect

11
State v. Rissleygreen
wisctapp · 2012 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018See State v. Rissley , 2012 WI App 112 , ¶ 19, 344 Wis. 2d 422 , 824 N.W.2d 853 ("[U]nder the collective knowledge doctrine, '[t]he police force is considered as a unit and where there is police-channel communication to the arresting officer and he acts in good faith thereon, the arrest is based on probable cause when such facts exist within the police department.' The same reasoning applies to cases involving investigatory stops based on reasonable suspicion." (citations omitted) ). ¶ 14 From the exchange between dispatch and the 911 caller, a reasonable police officer would conclude that at

2018See State v. Rissley , 2012 WI App 112 , ¶ 19, 344 Wis. 2d 422 , 824 N.W.2d 853 ("[U]nder the collective knowledge doctrine, '[t]he police force is considered as a unit and where there is police-channel communication to the arresting officer and he acts in good faith thereon, the arrest is based on probable cause when such facts exist within the police department.' The same reasoning applies to cases involving investigatory stops based on reasonable suspicion." (citations omitted) ). ¶ 14 From the exchange between dispatch and the 911 caller, a reasonable police officer would conclude that at

11
State v. Fridaygreen
wis · 1989 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018We noted that in order for the doctrine to apply, "such information must actually be passed to the officer before he or she makes an arrest or conducts a search." Id. , ¶17 n.4; see also State v. Friday , 140 Wis. 2d 701 , 712, 412 N.W.2d 540 (Ct. App. 1987), rev'd on other grounds , State v. Friday , 147 Wis. 2d 359 , 434 N.W.2d 85 (1989) (citation omitted) (noting that "[i]n addition to examining the totality of the circumstances" we must also consider "the degree of communication between" the police officers, rather than the "sole knowledge" of one officer). ¶28 We disagree that the collect

2018We noted that in order for the doctrine to apply, "such information must actually be passed to the officer before he or she makes an arrest or conducts a search." Id. , ¶17 n.4; see also State v. Friday , 140 Wis. 2d 701 , 712, 412 N.W.2d 540 (Ct. App. 1987), rev'd on other grounds , State v. Friday , 147 Wis. 2d 359 , 434 N.W.2d 85 (1989) (citation omitted) (noting that "[i]n addition to examining the totality of the circumstances" we must also consider "the degree of communication between" the police officers, rather than the "sole knowledge" of one officer). ¶28 We disagree that the collect

11
State v. Walkergreen
wis · 1990 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018See Black , 238 Wis. 2d 203 , ¶¶2-3, 17 n.4. ¶29 In Schaffer v. State , 75 Wis. 2d 673 , 250 N.W.2d 326 (1977), overruled on other grounds by State v. Walker , 154 Wis. 2d 158 , 185-86, 453 N.W.2d 127 (1990), for example, the arresting officer was shown a "teletype message from the Oshkosh Police Department which stated that a drugstore had been robbed in Oshkosh on January 7, 1975.

2018See Black , 238 Wis. 2d 203 , ¶¶2-3, 17 n.4. ¶29 In Schaffer v. State , 75 Wis. 2d 673 , 250 N.W.2d 326 (1977), overruled on other grounds by State v. Walker , 154 Wis. 2d 158 , 185-86, 453 N.W.2d 127 (1990), for example, the arresting officer was shown a "teletype message from the Oshkosh Police Department which stated that a drugstore had been robbed in Oshkosh on January 7, 1975.

11
Schaffer v. Stategreen
wis · 1977 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018See Black , 238 Wis. 2d 203 , ¶¶2-3, 17 n.4. ¶29 In Schaffer v. State , 75 Wis. 2d 673 , 250 N.W.2d 326 (1977), overruled on other grounds by State v. Walker , 154 Wis. 2d 158 , 185-86, 453 N.W.2d 127 (1990), for example, the arresting officer was shown a "teletype message from the Oshkosh Police Department which stated that a drugstore had been robbed in Oshkosh on January 7, 1975.

2018See Black , 238 Wis. 2d 203 , ¶¶2-3, 17 n.4. ¶29 In Schaffer v. State , 75 Wis. 2d 673 , 250 N.W.2d 326 (1977), overruled on other grounds by State v. Walker , 154 Wis. 2d 158 , 185-86, 453 N.W.2d 127 (1990), for example, the arresting officer was shown a "teletype message from the Oshkosh Police Department which stated that a drugstore had been robbed in Oshkosh on January 7, 1975.

11
State v. Fridaygreen
wisctapp · 1987 · cited in 1 Wisconsin opinions naming this issue, 2018–2018
2 sentences

2018We noted that in order for the doctrine to apply, "such information must actually be passed to the officer before he or she makes an arrest or conducts a search." Id. , ¶17 n.4; see also State v. Friday , 140 Wis. 2d 701 , 712, 412 N.W.2d 540 (Ct. App. 1987), rev'd on other grounds , State v. Friday , 147 Wis. 2d 359 , 434 N.W.2d 85 (1989) (citation omitted) (noting that "[i]n addition to examining the totality of the circumstances" we must also consider "the degree of communication between" the police officers, rather than the "sole knowledge" of one officer). ¶28 We disagree that the collect

2018We noted that in order for the doctrine to apply, "such information must actually be passed to the officer before he or she makes an arrest or conducts a search." Id. , ¶17 n.4; see also State v. Friday , 140 Wis. 2d 701 , 712, 412 N.W.2d 540 (Ct. App. 1987), rev'd on other grounds , State v. Friday , 147 Wis. 2d 359 , 434 N.W.2d 85 (1989) (citation omitted) (noting that "[i]n addition to examining the totality of the circumstances" we must also consider "the degree of communication between" the police officers, rather than the "sole knowledge" of one officer). ¶28 We disagree that the collect

11
Donald Tangwall v. Thomas Stuckeygreen
ca7 · 1998 · cited in 1 Wisconsin opinions naming this issue, 2009–2009
1 sentence

2009See Tangwall v. *235 Stuckey, 135 F.3d 510, 517 (7th Cir. 1998) (where arresting officer does not personally know the facts, an arrest is proper if the knowledge of the officer directing the arrest, or the collective knowledge of police, is sufficient to constitute probable cause). ¶ 13.

11
State v. Cheersgreen
wis · 1981 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
2 sentences

2006See State v. Cheers, 102 Wis. 2d 367, 389 , 306 N.W.2d 676 (1981) ("Where an officer relies upon a police communication in making an arrest, in the absence of his personal knowledge of probable cause, the arrest will only be based on probable cause, and thus valid, when such facts exist within the police department." (Citations omitted.)). 4 We stress that the propriety of the initial stop is not at issue; the detention to which we here refer is that which existed *109 after the business of the traffic stop had concluded.

2006See State v. Cheers, 102 Wis. 2d 367, 389 , 306 N.W.2d 676 (1981) ("Where an officer relies upon a police communication in making an arrest, in the absence of his personal knowledge of probable cause, the arrest will only be based on probable cause, and thus valid, when such facts exist within the police department." (Citations omitted.)). 4 We stress that the propriety of the initial stop is not at issue; the detention to which we here refer is that which existed *109 after the business of the traffic stop had concluded.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wisconsin. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
State v. Gant green
wisctapp · 2015
2 sentences

2025I have no—I don’t know what they’re doing, they fight all the time but it doesn’t normally get this loud.” The neighbor then agreed with the 911 operator that it “sounds like it’s physical.” Finally, even if we were to completely disregard the information regarding that second phone call and only rely on the information contained in the 911 call as outlined in the complaint, which was known to law enforcement before they encountered Wilkie, see State v. Gant, 2015 WI App 83, ¶12 , 365 Wis. 2d 510 , 872 N.W.2d 137 (noting that under the collective knowledge doctrine, a court may take into accou

2025I have no—I don’t know what they’re doing, they fight all the time but it doesn’t normally get this loud.” The neighbor then agreed with the 911 operator that it “sounds like it’s physical.” Finally, even if we were to completely disregard the information regarding that second phone call and only rely on the information contained in the 911 call as outlined in the complaint, which was known to law enforcement before they encountered Wilkie, see State v. Gant, 2015 WI App 83, ¶12 , 365 Wis. 2d 510 , 872 N.W.2d 137 (noting that under the collective knowledge doctrine, a court may take into accou

22024–2025
State v. Secrist green
wis · 1999
2 sentences

2022“Probable cause to arrest is the quantum of evidence within the arresting officer’s knowledge at the time of the arrest which would lead a reasonable police officer to believe that the defendant probably committed or was committing a crime.” State v. Secrist, 224 Wis. 2d 201, ¶19 , 589 N.W.2d 387 (1999).

2022“Probable cause to arrest is the quantum of evidence within the arresting officer’s knowledge at the time of the arrest which would lead a reasonable police officer to believe that the defendant probably committed or was committing a crime.” State v. Secrist, 224 Wis. 2d 201, ¶19 , 589 N.W.2d 387 (1999).

22018–2022
State v. Wille green
wisctapp · 1994
2 sentences

2019State v. Wille , 185 Wis. 2d 673 , 683, 518 N.W.2d 325 (Ct. App. 1994).

2019State v. Wille , 185 Wis. 2d 673 , 683, 518 N.W.2d 325 (Ct. App. 1994).

22000–2019
State v. Orta green
wis · 2000
2 sentences

2009For the above reasons, we reverse the judgment, affirm the order in part and reverse it in part, and remand with directions to suppress the evidence obtained from Pickens and from the safe inside the hotel room, but not the evidence found in the room apart from the safe. *249 By the Court. — Judgment reversed; order affirmed in part, reversed in part and cause remanded with directions. 1 See State v. Alexander, 2005 WI App 231, ¶ 13 , 287 Wis. 2d 645 , 706 N.W.2d 191 (" 'Under the collective knowledge doctrine, there are situations in which the information in the hands of an entire police depa

2009For the above reasons, we reverse the judgment, affirm the order in part and reverse it in part, and remand with directions to suppress the evidence obtained from Pickens and from the safe inside the hotel room, but not the evidence found in the room apart from the safe. *249 By the Court. — Judgment reversed; order affirmed in part, reversed in part and cause remanded with directions. 1 See State v. Alexander, 2005 WI App 231, ¶ 13 , 287 Wis. 2d 645 , 706 N.W.2d 191 (" 'Under the collective knowledge doctrine, there are situations in which the information in the hands of an entire police depa

22005–2009
State v. Nieves green
wisctapp · 2007
2 sentences

2025Cf. State v. Alexander, 2005 WI App 231, ¶13 , 287 Wis. 2d 645 , 706 N.W.2d 191 (“Under the collective knowledge doctrine, there are situations in which the information in the hands of an entire police department may be imputed to officers on the scene to help establish reasonable suspicion or probable cause.” (citation omitted)). 11 No. 2023AP543-CR ¶29 Given this evidence, we conclude that the circuit court properly refused to suppress Nero’s blood test results.10 “Probable cause is a flexible, commonsense standard” that “requires only that the facts available to the officer would warrant a

2025Cf. State v. Alexander, 2005 WI App 231, ¶13 , 287 Wis. 2d 645 , 706 N.W.2d 191 (“Under the collective knowledge doctrine, there are situations in which the information in the hands of an entire police department may be imputed to officers on the scene to help establish reasonable suspicion or probable cause.” (citation omitted)). 11 No. 2023AP543-CR ¶29 Given this evidence, we conclude that the circuit court properly refused to suppress Nero’s blood test results.10 “Probable cause is a flexible, commonsense standard” that “requires only that the facts available to the officer would warrant a

12025–2025
State v. Kutz green
wisctapp · 2003
2 sentences

2024Although prior criminal history may not in itself provide reasonable suspicion, it may be “considered as part of the totality of circumstances a reasonable officer takes into account[.]” State v. Kutz, 2003 WI App 205 , ¶17 n.4, 267 Wis. 2d 531 , 671 N.W.2d 660 .

2024Although prior criminal history may not in itself provide reasonable suspicion, it may be “considered as part of the totality of circumstances a reasonable officer takes into account[.]” State v. Kutz, 2003 WI App 205 , ¶17 n.4, 267 Wis. 2d 531 , 671 N.W.2d 660 .

12024–2024
State v. Young green
wisctapp · 1997
2 sentences

2024“The question of what constitutes reasonable suspicion is a common sense test: under all the facts and circumstances present, what would a reasonable police officer reasonably suspect in light of his or her training and experience[?]” State v. Young, 212 Wis. 2d 417, 424 , 569 N.W.2d 84 (Ct. App. 1997). ¶21 The State argues that the vehicle search was supported by reasonable suspicion based on the collective knowledge of Chief Bauer and Officer Schuld. 8 No. 2023AP351-CR See State v. Gant, 2015 WI App 83, ¶12 , 365 Wis. 2d 510 , 872 N.W.2d 137 (under the collective knowledge doctrine, in deter

2024“The question of what constitutes reasonable suspicion is a common sense test: under all the facts and circumstances present, what would a reasonable police officer reasonably suspect in light of his or her training and experience[?]” State v. Young, 212 Wis. 2d 417, 424 , 569 N.W.2d 84 (Ct. App. 1997). ¶21 The State argues that the vehicle search was supported by reasonable suspicion based on the collective knowledge of Chief Bauer and Officer Schuld. 8 No. 2023AP351-CR See State v. Gant, 2015 WI App 83, ¶12 , 365 Wis. 2d 510 , 872 N.W.2d 137 (under the collective knowledge doctrine, in deter

12024–2024
State v. Young green
wis · 2006
2 sentences

2020State v. Pickens, 2010 WI App 5, ¶12 , 323 Wis. 2d 226 , 779 N.W.2d 1 (2009). ¶13 Probable cause does not require proof “beyond a reasonable doubt or even that guilt is more likely than not.” State v. Young, 2006 WI 98, ¶22 , 294 Wis. 2d 1 , 717 N.W.2d 729 .

2020State v. Pickens, 2010 WI App 5, ¶12 , 323 Wis. 2d 226 , 779 N.W.2d 1 (2009). ¶13 Probable cause does not require proof “beyond a reasonable doubt or even that guilt is more likely than not.” State v. Young, 2006 WI 98, ¶22 , 294 Wis. 2d 1 , 717 N.W.2d 729 .

12020–2020
Katz v. United States green
scotus · 1967
1 sentence

2018He first claims that the search of his vehicle incident to his arrest was unlawful. 9 Searches conducted without a warrant are per se unreasonable, "subject only to a few specifically established and well-delineated exceptions." Katz v. United States , 389 U.S. 347 , 357 (1967).

12018–2018
Prado Navarette v. California green
scotus · 2014
1 sentence

2018The 911 caller further indicated that the girl's basis of knowledge came from her own contemporaneous experience as she purportedly told the 911 caller that her mother was at that time driving drunk with her and her siblings, and thus the girl "necessarily claimed eyewitness knowledge of the alleged dangerous driving." See Navarette v. California , 572 U.S. 393 , 399 (2014).

12018–2018

Statutes the citing opinions construe

WI § Wis. Stat. § 808.10 (7) WI § Wis. Stat. § 752.31 (5) WI § Wis. Stat. § 971.31 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 22 (2015–2025) OH 16 (2011–2026) PA 15 (2015–2025) WI 15 (2000–2025) MA 10 (1994–2024) OR 9 (2000–2025) DC 9 (1993–2025) IL 8 (2007–2026) IN 7 (2012–2025) CA 7 (2002–2021) CT 6 (2007–2019) ID 6 (2018–2026) NV 5 (2018–2018) DE 5 (2015–2025) VA 4 (2016–2021) MN 4 (2010–2014) KY 4 (2017–2023) KS 4 (2013–2024) MD 3 (1992–2025) OK 3 (2014–2021) NE 3 (2021–2023) WY 3 (2019–2022) UT 3 (2007–2011) IA 2 (1981–2016) SD 2 (1998–2013) AK 2 (2018–2018) GA 2 (2007–2015) ND 2 (1989–2008) MI 2 (1993–2003) TN 2 (2019–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check