collective knowledge doctrine in District of Columbia

2020That information thus factors into the probable cause to arrest calculus, regardless of whether Officer Rubin himself was aware of the recovery. between the statements above because, as discussed below, we find In re M.E.B., 638 A.2d 1123 , 1132–33 (D.C. 1993), to be controlling here. 15 We do not address the force of the collective knowledge doctrine where an officer is not merely effectuating other officers’ directives but exceeds the bounds of (or even contravenes) those directives.

2011The doctrine of collective knowledge is “firmly established in this jurisdiction,” and provides that although individual officers may not have sufficient knowledge to establish probable cause, the “information collectively known, even if not communicated by one officer to the other, [can be] sufficient.” In re M.E.B., 638 A.2d 1123, 1129-30 (D.C.1993); see also Smith v. United States, 358 F.2d 833, 835 (D.C.Cir.1966) (“The correct test is whether a warrant if sought could, have been obtained by law enforcement agency application which disclosed its corporate information, not whether any one pa

2025The facts of Haywood, however, were quite unique, involving the arrest of an individual who was on the scene when police officers responded to a lookout for a different individual and an arresting officer who acted without any direction at all. 584 A.2d at 553, 556-57 .

2020Compare Haywood v. United States, 584 A.2d 552, 557 (D.C. 1990) (“In cases such as this where probable cause for arrest is predicated in part on the personal observations of the arresting officer, the court may not rely on facts which were available to other officers at the scene unless that information was communicated to the arresting officer.”), with Tetaz v. District of Columbia, 976 A.2d 907 , 914 n.7 (D.C. 2009) (“It does not matter that the particular officers on duty at the Russell Building may not have known of the activity inside the Hart Building.

1993See People v. Ford, 150 Cal. App.3d 687 , 198 Cal.Rptr. 80, 88 (1984).

1993See People v. Ford, 150 Cal. App.3d 687 , 198 Cal.Rptr. 80, 88 (1984).

2020Cir. 1966) (“[P]robable cause is to be evaluated . . . on the basis of the collective information of the police” instead of just the arresting officer’s knowledge.); Parsons v. United States, 15 A.3d 276, 279 (D.C. 2011) (explaining the collective knowledge doctrine is “firmly established” to allow information collectively known amongst officers to provide probable cause); Prince v. United States, 825 A.2d 928 , 932–33 (D.C. 2003) (concluding there was sufficient probable cause even though the arresting officer’s knowledge taken alone would not suffice).

2020Compare Haywood v. United States, 584 A.2d 552, 557 (D.C. 1990) (“In cases such as this where probable cause for arrest is predicated in part on the personal observations of the arresting officer, the court may not rely on facts which were available to other officers at the scene unless that information was communicated to the arresting officer.”), with Tetaz v. District of Columbia, 976 A.2d 907 , 914 n.7 (D.C. 2009) (“It does not matter that the particular officers on duty at the Russell Building may not have known of the activity inside the Hart Building.

2017See, e.g., In re S.B., 44 A.3d 948 , 951 (D.C. 2012) (reversing conviction when lookout was for juvenile black male with white pants, messing about in a public park); In re T.L.L., 729 A.2d at 340.

2017See, e.g., In re S.B., 44 A.3d 948 , 951 (D.C. 2012) (reversing conviction when lookout was for juvenile black male with white pants, messing about in a public park); In re T.L.L., 729 A.2d at 340.

2011The doctrine of collective knowledge is “firmly established in this jurisdiction,” and provides that although individual officers may not have sufficient knowledge to establish probable cause, the “information collectively known, even if not communicated by one officer to the other, [can be] sufficient.” In re M.E.B., 638 A.2d 1123, 1129-30 (D.C.1993); see also Smith v. United States, 358 F.2d 833, 835 (D.C.Cir.1966) (“The correct test is whether a warrant if sought could, have been obtained by law enforcement agency application which disclosed its corporate information, not whether any one pa

2011The Fourth Amendment protects a person “from unreasonable searches and seizures, and the reasonableness of an infringement on personal liberty is determined by whether the information on which the police acted provided reasonable articulable suspicion or probable cause.” United States v. Boxley, 985 A.2d 1108, 1111-12 (D.C.2009) (quotation marks omitted).

2006Moreover, Mr. McMillian insists that the government has waived the argument “that even if the police violated [Mr.] McMillian’s Fourth Amendment rights, the ensuing statement was too attenuated from the illegality to be suppressed.” The sole focus of the hearing before Judge Winston, he argues, “was to adduce evidence of probable cause” and “the government did not seek leave to expand its arguments to include attenuation.” “Although this court defers to relevant factual findings by the trial court, we review de novo the ultimate question of whether a seizure was supported by reasonable suspici

2006Moreover, Mr. McMillian insists that the government has waived the argument “that even if the police violated [Mr.] McMillian’s Fourth Amendment rights, the ensuing statement was too attenuated from the illegality to be suppressed.” The sole focus of the hearing before Judge Winston, he argues, “was to adduce evidence of probable cause” and “the government did not seek leave to expand its arguments to include attenuation.” “Although this court defers to relevant factual findings by the trial court, we review de novo the ultimate question of whether a seizure was supported by reasonable suspici

2001See generally Illinois v. Andreas, 463 U.S. 765 , 771 n. 5, 103 S.Ct. 3319 , 77 L.Ed.2d 1003 (1983).

2001See generally Illinois v. Andreas, 463 U.S. 765 , 771 n. 5, 103 S.Ct. 3319 , 77 L.Ed.2d 1003 (1983).

1995See In re M.E.B., 638 A.2d 1123, 1128-33 (D.C.1993), cert. denied, - U.S. -, 115 S.Ct. 221 , 130 L.Ed.2d 148 (1994).

1995See In re M.E.B., 638 A.2d 1123, 1128-33 (D.C.1993), cert. denied, ___ U.S. ___, 115 S.Ct. 221 , 130 L.Ed.2d 148 (1994).