On Point blog, page 2 of 2
State v. Sameeh J. Pickens, 2010 WI App 5, reconsideration denied
court of appeals decision; for Pickens: Eileen A. Hirsch, SPD, Madison Appellate
Reasonable Suspicion for Detention and “Collective Knowledge” Doctrine
Although, “under the collective knowledge doctrine, an investigating officer with knowledge of facts amounting to reasonable suspicion may direct a second officer without such knowledge to stop and detain a suspect,” the state must prove those underlying facts. “Proof is not supplied by the mere testimony of one officer that he relied on the unspecified knowledge of another officer,” ¶¶12-13.
Consent to Search – Apparent Authority: Owner of Residence, Allowing Search of Renter’s Room
State v. Roemie T. St. Germaine, 2007 WI App 214, PFR filed 9/27/07
For St. Germaine: Rex Anderegg
Issue: Whether the owner of the residence (Briseno) had apparent authority to consent to police search of renter St. Germaine’s room, at least where St. Germaine was present was consent was sought and never objected.
Holding:
¶17 St. Germaine argues that there was no reasonable basis for the officers to search his room because they knew it was rented and that Briseno could not consent.