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

collective knowledge doctrine in Oregon

9 Oregon opinions name it 3 courts 2000–2025 2 in the last five years

The cases below were cited by Oregon 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 (6)

CaseFollowedCited
State v. Soldahlgreen
or · 2000 · cited in 6 Oregon opinions naming this issue, 2008–2016
2 sentences

2011It is, therefore, a fact that supports the officers’ reasonable belief based on Benny’s alert that illegal drugs or other seizable evidence probably will be found in the place to be searched. 11 The collective knowledge doctrine “focuses on the shared knowledge of the police as a unit rather than merely on the knowledge of the officer who acts.” State v. Soldahl, 331 Or 420, 427 , 15 P3d 564 (2000).

2011It is, therefore, a fact that supports the officers’ reasonable belief based on Benny’s alert that illegal drugs or other seizable evidence probably will be found in the place to be searched. 11 The collective knowledge doctrine “focuses on the shared knowledge of the police as a unit rather than merely on the knowledge of the officer who acts.” State v. Soldahl, 331 Or 420, 427 , 15 P3d 564 (2000).

36
State v. Lichtygreen
or · 1992 · cited in 2 Oregon opinions naming this issue, 2014–2014
2 sentences

2014See generally Lichty, 313 Or at 585 (totality of circumstances considered by police officers included reasonable reliance on information from informant).

2014See generally Lichty, 313 Or at 585 (totality of circumstances considered by police officers included reasonable reliance on information from informant).

22
State v. Prattgreen
or · 1990 · cited in 4 Oregon opinions naming this issue, 2000–2016
2 sentences

2008By virtue of the collective knowledge doctrine, however, “[a] peace officer who does not himself have probable cause to arrest a felony suspect nonetheless may arrest the suspect if he reasonably believes that the officer or officers who have requested the arrest do have probable cause to make that arrest and if probable cause to arrest does, in fact, exist.” State v. Pratt, 309 Or 205, 216 , 785 P2d 350 (1990) (emphasis in original).

2008By virtue of the collective knowledge doctrine, however, “[a] peace officer who does not himself have probable cause to arrest a felony suspect nonetheless may arrest the suspect if he reasonably believes that the officer or officers who have requested the arrest do have probable cause to make that arrest and if probable cause to arrest does, in fact, exist.” State v. Pratt, 309 Or 205, 216 , 785 P2d 350 (1990) (emphasis in original).

14
State v. Grodagreen
or · 1979 · cited in 3 Oregon opinions naming this issue, 2000–2016
2 sentences

2008Defendant relies primarily on the following language from State v. Groda, 285 Or 321, 324 , 591 P2d 1354 (1979): “We understand [the collective knowledge rule] to be that the searching officer personally must have information which constitutes probable cause, or the searching officer must be directed to make the search by an officer who personally has that knowledge.

2008Defendant relies primarily on the following language from State v. Groda, 285 Or 321, 324 , 591 P2d 1354 (1979): “We understand [the collective knowledge rule] to be that the searching officer personally must have information which constitutes probable cause, or the searching officer must be directed to make the search by an officer who personally has that knowledge.

13
State v. Holdorfgreen
or · 2014 · cited in 2 Oregon opinions naming this issue, 2014–2016
2 sentences

2016See State v. Holdorf, 355 Or 812, 825 , 333 P3d 982 (2014) (“[T]he collective knowledge doctrine *** applies when a police officer reasonably relies on information from other officers in making a determination that a stop is justified based on articulable facts that criminal activity is afoot”).

2016See State v. Holdorf, 355 Or 812, 825 , 333 P3d 982 (2014) (“[T]he collective knowledge doctrine *** applies when a police officer reasonably relies on information from other officers in making a determination that a stop is justified based on articulable facts that criminal activity is afoot”).

12
State v. Mickelsongreen
orctapp · 1974 · cited in 1 Oregon opinions naming this issue, 2016–2016
2 sentences

2016See State v. Groda, 285 Or 321, 324 , 591 P2d 1354 (1979) (expressly adopting rule applied in State v. Mickelson, 18 Or App 647, 650-51 , 526 P2d 583 (1974), and articulating that rule as follows: “[T]he searching officer personally must have information which constitutes probable cause, or the searching officer must be directed to make the search by an officer who personally has that knowledge.

2016See State v. Groda, 285 Or 321, 324 , 591 P2d 1354 (1979) (expressly adopting rule applied in State v. Mickelson, 18 Or App 647, 650-51 , 526 P2d 583 (1974), and articulating that rule as follows: “[T]he searching officer personally must have information which constitutes probable cause, or the searching officer must be directed to make the search by an officer who personally has that knowledge.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
State v. Rhyne neutral
orctapp · 2018
2 sentences

2025R., 290 Or App 827, 833 , 417 P3d 422 , rev den, 363 Or 481 (2018) (explaining that the collective knowledge doctrine permits an officer to rely on information from other officers when determining reasonable suspicion for a stop).

2025R., 290 Or App 827, 833 , 417 P3d 422 , rev den, 363 Or 481 (2018) (explaining that the collective knowledge doctrine permits an officer to rely on information from other officers when determining reasonable suspicion for a stop).

12025–2025
Molette v. Nooth green
or · 2018
1 sentence

2025R., 290 Or App 827, 833 , 417 P3d 422 , rev den, 363 Or 481 (2018) (explaining that the collective knowledge doctrine permits an officer to rely on information from other officers when determining reasonable suspicion for a stop).

12025–2025
State v. Shannon neutral
orctapp · 2025
1 sentence

2025Nonprecedential Memo Op: 345 Or App 292 (2025) 295 We reject defendant’s contention that Brown requires a different conclusion.

12025–2025
State v. Russum green
orctapp · 2014
1 sentence

2024That doctrine is no more applicable here than it was in Russum. 265 Or App at 119 . 192 State v. Greenwood know about the recordings, that they did not listen to them, and that no one ever told them what was in the calls.

12024–2024
State v. Radford neutral
orctapp · 2008
2 sentences

2016State v. Soldahl, 331 Or 420, 427 , 15 P3d 564 (2000) (“[T]he [collective knowledge] doctrine permits a police officer to [arrest a suspect] if the officer reasonably relies on instructions from an officer who has probable cause.”); State v. Radford, 222 Or App 87, 89 , 191 P3d 776 (2008) (“‘[A] peace officer who does not himself have probable cause to arrest a felony suspect nonetheless may arrest the suspect if he reasonably believes that the officer or officers who have requested the arrest do have probable cause to make that arrest and if probable cause to arrest does, in fact, exist.’” (Q

2016State v. Soldahl, 331 Or 420, 427 , 15 P3d 564 (2000) (“[T]he [collective knowledge] doctrine permits a police officer to [arrest a suspect] if the officer reasonably relies on instructions from an officer who has probable cause.”); State v. Radford, 222 Or App 87, 89 , 191 P3d 776 (2008) (“‘[A] peace officer who does not himself have probable cause to arrest a felony suspect nonetheless may arrest the suspect if he reasonably believes that the officer or officers who have requested the arrest do have probable cause to make that arrest and if probable cause to arrest does, in fact, exist.’” (Q

12016–2016
State v. Owens green
or · 1986
2 sentences

2008The collective knowledge doctrine, also known as the fellow-officer rule, adds a gloss to the well-settled rule that probable cause to execute an arrest requires both a subjective and an objective component: “An officer must subjectively believe that a crime has been committed and thus that a person or thing is subject to seizure, and this belief must be objectively reasonable in the circumstances.” *90 State v. Owens, 302 Or 196, 204 , 729 P2d 524 (1986).

2008The collective knowledge doctrine, also known as the fellow-officer rule, adds a gloss to the well-settled rule that probable cause to execute an arrest requires both a subjective and an objective component: “An officer must subjectively believe that a crime has been committed and thus that a person or thing is subject to seizure, and this belief must be objectively reasonable in the circumstances.” *90 State v. Owens, 302 Or 196, 204 , 729 P2d 524 (1986).

12008–2008
State v. Koester green
orctapp · 1992
2 sentences

2000That court reasoned that an essential element of the collective knowledge doctrine is that an officer who makes a stop for a traffic infraction must himself or herself “ ‘subjectively believe’ that the requesting officer had sufficient grounds for the arrest or stop.” Id. (citing State v. Koester, 117 Or App 139, 144 , 843 P2d 968 (1992)) (emphasis in original).

2000That court reasoned that an essential element of the collective knowledge doctrine is that an officer who makes a stop for a traffic infraction must himself or herself “ ‘subjectively believe’ that the requesting officer had sufficient grounds for the arrest or stop.” Id. (citing State v. Koester, 117 Or App 139, 144 , 843 P2d 968 (1992)) (emphasis in original).

12000–2000
State v. Soldahl green
orctapp · 1998
2 sentences

2000That court reasoned that an essential element of the collective knowledge doctrine is that an officer who makes a stop for a traffic infraction must himself or herself “ ‘subjectively believe’ that the requesting officer had sufficient grounds for the arrest or stop.” Id. (citing State v. Koester, 117 Or App 139, 144 , 843 P2d 968 (1992)) (emphasis in original).

2000Soldahl, 157 Or App at 584 .

12000–2000

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 131.615 (3) OR § Or. Rev. Stat. § 135.335 (3)

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