Reversal: IDACS error no basis to suppress meth evidence

Southern Indiana authorities who arrested a man for buying pseudoephedrine had probable cause even though the suspect had not been convicted of a prior methamphetamine charge, as a state database reported.

The Indiana Court of Appeals on Friday reversed a Perry Circuit Court order suppressing evidence in State of Indiana v. William F. Stevens, 62A01-1406-CR-268. William Stevens was arrested at a drugstore after purchasing the meth precursor. Police found a report of a Florida meth conviction in the Indiana Data and Communication System. But the IDACS entry was wrong; Stevens had been convicted of dealing Xanax.

Stevens was on the law enforcement radar because his name showed up in pharmacy purchase logs due to suspicious purchases of pseudoephedrine, a precursor to meth, at Tell City drugstores. After his arrest, Stevens was charged with four felonies when police found meth and paraphernalia in a subsequent search of his home.  

The trial court granted Stevens’ motion to suppress based on the errant criminal history reported in IDACS. He argued officers should not have merely relied on the criminal record in the database without further researching the conviction.

But Judge Paul Mathias wrote for the panel that officers acted with good faith reliance, the test established in Moody v. State, 448 N.E.2d 660, 663 (Ind. 1983).

“We find Moody to be controlling in this case and conclude that under both the Fourth Amendment and Article 1, Section 11, it was reasonable for law enforcement officers to believe that the information they received from IDACS, namely that Stevens had a prior conviction for dealing in methamphetamine, was accurate,” Mathias wrote. “…This reasonable belief was sufficient to provide probable cause to believe that Stevens was committing a crime by attempting to purchase pseudoephedrine.

“(U)nder the unique facts and circumstances before us, we conclude that the trial court abused its discretion in granting Stevens’s motion to suppress," Mathias wrote for the panel.

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