Tulsa County Deputy Freddie Alaniz knew one thing about the Mazda SUV on a highway near Tulsa: it had a California plate. The federal court record says that was the only reason he followed it. He ran the plate through Flock’s database, picked “traffic violation” and “investigation” as his reasons for the search, and got back more than 50 sightings across multiple states. Then he stopped the driver, Melisa Kyle, for following another car too closely, gave her a written warning, and held her at the roadside for a drug dog.
On Oct. 1, U.S. District Judge Sara E. Hill suppressed the evidence in United States v. Kyle, a Northern District of Oklahoma case (No. 26-CR-00189-SEH). The order makes two findings that pull in different directions. The stop was justified when it began. The Flock query that came before it was a Fourth Amendment search conducted without a warrant or probable cause.
Why the stop survived and the lookup did not
Alaniz cited two violations: failing to signal at least 100 feet before several lane changes, and following too closely, which he put at about 30 feet between vehicles. Hill relied only on the second and found it gave him an objectively reasonable basis for the stop. The California plate that made him notice the car did not matter to that question. The rule comes from Whren v. United States, a unanimous 1996 decision written by Justice Scalia holding that a stop supported by probable cause of a traffic violation is valid even if the officer had some other objective. “Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis,” the opinion says…