The Fellow Officer (Collective Knowledge) Rule

When examining whether an officer has sufficient information to detain, arrest, or search, (i.e., reasonable suspicion and/or probable cause) the officer need not know every fact personally.  That information may be provided by other officers.  This is not just a hearsay-type rule (where one officer tells the other certain facts).  In fact, the fellow officer rule permits “an officer having probable cause or reasonable suspicion [to instruct] another officer to act, even without communicating all of the information necessary to justify the action." 

Legal Supplement

Holt v. State, 1973 OK CR 38, ¶ 14, It is well settled that an agent may rely upon his fellow officers to supply the information which forms the basis of the arresting officer's reasonable grounds for believing that the law is being violated.

Fuentes v. State, 2021 OK CR 38, This legal rule [collective knowledge/fellow officer], which imputes reasonable suspicion or probable cause possessed by one officer or group, to another officer who actually conducts a search or seizure, has a pedigree in this court nearly five decades old.

Generally stated, the doctrine allows an officer to stop, arrest, or search a suspect in limited circumstances, even if the officer does not have firsthand knowledge of all of the facts that amount to reasonable suspicion or probable cause to justify the action. This principle derives from the recognition that law enforcement officers must be permitted to work collectively in the performance of their duties and act on directions and information given by one officer to another. 

The collective knowledge doctrine has both vertical and horizontal application. The vertical application, implicated here, occurs "when an officer having probable cause or reasonable suspicion instructs another officer to act, even without communicating all of the information necessary to justify the action." United States v. Whitley, 680 F.3d 1227, 1234 (10th Cir. 2012).3 The officer taking action does not need to personally be aware of all the facts justifying the detention because "officers, who must often act swiftly, cannot be expected to cross-examine their fellow officers about the foundation for the transmitted information." United States v. Hensley, 469 U.S. 221, 231 (1985) (quoting United States v. Robinson, 536 F.2d 1298, 1299 (9th Cir. 1976)).