State v. Beck (Kan. 2025): No State-Name Requirement on License Plates; Totality-of-the-Circumstances Standard Replaces “Safe Following Distance” Test

Introduction

In State v. Beck, No. 126,350 (Kan. Oct. 10, 2025) (modified opinion), the Kansas Supreme Court resolved a recurring Fourth Amendment and traffic-law question: does Kansas law require that the issuing state’s name on a license plate be visible and legible, such that a partial obstruction justifies a traffic stop? The court’s answer reshapes everyday policing and suppressions litigation across Kansas. It holds that Kansas statutes do not require the display of a state name on the face of a license plate (beyond the registration decal), rejects a long-used “safe following distance” visibility test created in federal district court, and replaces it with an objective totality-of-the-circumstances standard focused on whether the plate is “clearly legible” within the meaning of K.S.A. 8-133(c).

The case arose after a sheriff’s deputy stopped Brian Beck on I-70 because a license plate frame partially obscured the issuing state name on his Illinois plate. A dog sniff followed, the dog alerted, and a search revealed methamphetamine. Beck moved to suppress, the district court denied the motion, and the Court of Appeals affirmed. The Supreme Court granted review limited to the statutory interpretation issue and reversed, remanding for a new suppression hearing under the correct legal standard and for the district court to consider whether any exception to the exclusionary rule applies.

Summary of the Opinion

• Plain text controls: When a statute is plain and unambiguous, courts must not add requirements not found in its words.
• No Kansas requirement to display the state name on the plate face: Kansas law requires the state name only on the registration decal (and permits an abbreviation). No statute requires the state name to be printed or be legible elsewhere on the plate.
• New governing standard for stops under K.S.A. 8-133(c): Courts must assess, under an objective totality-of-the-circumstances standard, whether a reasonable officer would have reasonable suspicion that the plate was not “maintained free from foreign materials and in a condition to be clearly legible.” Viewing distance may be relevant, but is not controlling.
• Repudiation of the “safe following distance” rule: The court rejects the federal district court’s test from United States v. Unrau and its progeny, including its misquotation of State v. Hayes and its impractical “safe following distance” gloss.
• Out-of-state plates and jurisdiction: Kansas courts and law enforcement do not enforce other states’ penal laws. Obscured state names on nonresident plates do not violate Kansas law.
• Disposition: The district court’s denial of suppression and the Court of Appeals’ affirmance are reversed on the reviewed issue. The case is remanded for a new suppression hearing consistent with the court’s statutory interpretation, including consideration of any exclusionary-rule exceptions.

Detailed Analysis

1) Precedents and Authorities Cited and Their Role

• Statutory interpretation canon: State v. Kerrigan, 317 Kan. 683 (2023) and related decisions reinforce the plain-meaning rule: courts may not read into a statute what is not there. This frames the entire analysis of K.S.A. 8-133, 8-147, and 8-132.
• Fourth Amendment traffic-stop framework:
  • Terry v. Ohio, 392 U.S. 1 (1968): two-prong analysis for investigative detentions (justified at inception; reasonably related in scope).
  • Delaware v. Prouse, 440 U.S. 648 (1979): officers must have reasonable suspicion of a traffic or equipment violation to stop a car.
  • Kansas cases applying Terry/Prouse: State v. Sharp, 305 Kan. 1076 (2017); State v. Jones, 300 Kan. 630 (2014); State v. Morlock, 289 Kan. 980 (2009).
  • Standards of review and burdens: State v. Cash, 313 Kan. 121 (2021) (substantial competent evidence for facts, de novo for legal conclusions); State v. Goodro, 315 Kan. 235 (2022) (State’s burden to prove lawfulness of seizure).
• K.S.A. 8-133 and related statutes:
  • K.S.A. 8-133(c): Requires plates to be “fastened in a place and position to be clearly visible” and “maintained free from foreign materials and in a condition to be clearly legible.”
  • K.S.A. 8-147: Specifies what manufacturing must ensure is “easily read”: the alphanumeric characters; requires registration decals; says nothing about a legible printed state name on the plate face.
  • K.S.A. 8-132(a): Requires the “name of the state, which may be abbreviated,” and the year(s) of issue to be displayed on the registration decal.
  • K.S.A. 8-149: Makes violations a misdemeanor.
• Earlier Kansas and federal district court cases applying K.S.A. 8-133:
  • State v. Hayes, 8 Kan. App. 2d 531 (1983): Treated obscured state designation (Indiana) as justifying a stop; described statute’s public-safety/identification purpose; applied Kansas display law to out-of-state plates. The Supreme Court notes Hayes spoke of “legible” but did not say “all of the tag must be visible,” a misstatement later attributed to it by Unrau.
  • United States v. Unrau, 2003 WL 21667166 (D. Kan. 2003): Created a “safe following distance” test and misquoted Hayes; justified a stop where a ball hitch made the plate unreadable from a safe distance. The Kansas Supreme Court expressly rejects Unrau’s test as textually unfounded and impractical.
  • United States v. Carter, 2003 WL 22077684 (D. Kan. 2003): Suppressed evidence where an Ohio state name was half-obscured yet readable; found no probable cause/reasonable suspicion of a K.S.A. 8-133 violation. Beck’s reasoning aligns with Carter on this point.
  • Other federal district decisions following Unrau: Granados-Orozco (2003); Rubio-Sanchez (2006); Garcia-Medina (2007). The Supreme Court groups them as progeny of an improper test.
  • Kansas Court of Appeals: State v. Moss, No. 122,775, 2020 WL 7086182 (unpublished), one of several decisions influenced by Unrau.
• Jurisdiction over out-of-state laws:
  • In re Fowles, 89 Kan. 430 (1913); Machinery Co. v. Smith, 87 Kan. 331 (1912); State v. Verge, 316 Kan. 554 (2022): Kansas courts do not enforce other states’ penal laws; Kansas law governs the stop analysis in Kansas.
  • K.S.A. 8-138a: “Reciprocal privileges” for nonresident owners do not import foreign penal regulations into Kansas enforcement.

2) The Court’s Legal Reasoning

The court begins with the text of the governing statutes. K.S.A. 8-147 requires the letters and numerals on a Kansas license plate to be “easily read,” and it mandates a registration decal. K.S.A. 8-132(a) requires that the state’s name (which may be abbreviated) and the year(s) of issuance appear on the registration decal. No statute requires the state name to be printed, prominent, or legible on the face of the plate itself. In contrast, the alphanumeric identifier is the specific item that must be easy to read under K.S.A. 8-147.

Turning to K.S.A. 8-133(c), the court parses the statutory requirements: plates must be secured, clearly visible as to placement, and “maintained free from foreign materials and in a condition to be clearly legible.” The statute does not define “clearly visible,” “free from foreign materials,” or “clearly legible.” But reading K.S.A. 8-133(c) harmoniously with K.S.A. 8-147 and 8-132(a), the critical legibility refers to the information Kansas law requires to be legible for identification—the plate’s alphanumeric characters and, as applicable, the registration decal—not the issuing state’s name printed across the top or bottom band of a plate or specialty graphics.

Against that statutory backdrop, the court rejects the extra-textual “safe following distance” test introduced by Unrau. Unrau both added a condition the Legislature never enacted and misquoted Hayes as requiring that “all of the tag must be visible.” The Supreme Court notes the practical unworkability of a distance-dependent rule—legibility depends on speed, weather, lighting, plate design, and viewing angle—and instead adopts a familiar Fourth Amendment analytical posture:

• New operative standard: Whether, under the totality of the circumstances, a reasonable officer would have reasonable suspicion that the plate was not “maintained in a condition to be clearly legible.” Viewing distance can be relevant evidence but is not a controlling legal benchmark.

Applying this construction, the court holds that an officer’s reasonable suspicion cannot be grounded solely on the obstruction of a plate’s state name, because Kansas law does not require the state name to be displayed on the plate’s face at all (only on the registration decal). That conclusion renders the initial stop of Beck unlawful on the rationale used, absent other facts establishing reasonable suspicion of a different violation. The court emphasizes that Kansas officers cannot enforce Illinois’ license-plate visibility rules, and K.S.A. 8-138a’s “reciprocal privileges” provision does not change that.

Finally, the court reverses the suppression ruling and the convictions that turned on the fruits of the search, remanding for a new suppression hearing under the clarified standard, including whether any exception to the exclusionary rule (e.g., good faith, attenuation, independent source, inevitable discovery, or valid consent untainted by the stop) saves the evidence.

3) Practical Impact and Doctrinal Significance

• Immediate policing consequences:
  • In Kansas, a stop may not be premised solely on a frame or accessory that partially or fully obscures the printed state name on a plate. That condition is not a Kansas statutory violation.
  • Officers must instead assess whether the plate’s legally required identifiers—the alphanumeric characters and registration decal—are clearly legible, and whether the plate is “clearly visible” as to placement and mounting.
  • Distance-based, “I could not read it from a safe following distance” rationales are insufficient by themselves; officers should document the specific, objective circumstances demonstrating that required information was not clearly legible.
• Suppression litigation:
  • The opinion undercuts a line of federal district court and Kansas appellate decisions that had accepted Unrau’s distance-based rule. Defendants with cases on direct review may challenge stops premised solely on obscured state names.
  • On remand in Beck and in future cases, courts will parse the “foreign materials” and “clearly legible” requirements on a record-specific basis. The court did not define “foreign materials” or resolve whether common frames are per se “foreign materials”; rather, the touchstone remains whether required information is clearly legible under the totality of the circumstances.
  • Because the Supreme Court directed consideration of exclusionary-rule exceptions, litigants should be prepared to brief and prove (or rebut) exceptions such as attenuation or good-faith reliance. The court did not decide those issues.
• Out-of-state plates:
  • Kansas officers apply Kansas law; they cannot stop a vehicle merely because the plate would violate another state’s display rules (e.g., required state-name visibility) if Kansas law imposes no such requirement.
  • Obstruction of alphanumeric characters or registration decals on out-of-state plates can still justify a stop under Kansas law.
• Legislative implications:
  • If the Legislature wants state-name visibility to be enforceable, it can amend K.S.A. 8-133 or 8-147 to say so expressly and to define any distance or design standards. Absent such amendments, courts will not read that requirement into the statute.
• Training and policy updates:
  • Law-enforcement agencies should revise training materials and stop templates that referenced a “safe following distance” test or treated obscured state names as per se violations.
  • Officers should contemporaneously note which required elements (alphanumeric, decal content) were illegible and the specific conditions (e.g., mud, snow, tinted cover, obstruction by cargo or hitch) that impaired legibility.

Complex Concepts Simplified

• Reasonable suspicion: A particularized, objective basis to believe a traffic or equipment violation has occurred, based on specific facts—not a mere hunch.
• Totality of the circumstances: A holistic assessment of all facts and conditions (lighting, weather, distance, angle, obstructions, plate design) rather than application of a single bright-line metric.
• Clearly visible vs. clearly legible: “Clearly visible” in K.S.A. 8-133(c) concerns mounting and placement of the plate so it can be seen; “clearly legible” concerns whether the information that must be read (here, the alphanumeric identifier and relevant decal information) can be read. The statute does not require the printed state name on the plate face to be legible.
• Foreign materials: The statute requires plates be maintained free from foreign materials and clearly legible. The opinion does not define “foreign materials” or decide whether a plate frame is a per se violation; instead, legibility of required information remains central.
• Exclusionary rule and exceptions: If a stop is unconstitutional, evidence obtained may be suppressed unless an exception applies (e.g., good faith, attenuation, independent source, or inevitable discovery). The Supreme Court remanded for the district court to consider such questions.
• Reciprocal privileges (K.S.A. 8-138a): Nonresidents may operate vehicles in Kansas if duly licensed and registered in their home state; Kansas does not thereby enforce the home state’s penal regulations on plate display.

Key Passages and Their Significance

• “No statute requires displaying the Kansas state name anywhere other than on the registration decal, where it may be abbreviated.”
  This anchors the holding that obscuring the printed state name on the plate face is not a violation of Kansas law.
• “When deciding whether an officer has reasonable suspicion that a driver has violated K.S.A. 8-133(c), courts should apply the objective standard… under the totality of the circumstances… [whether] the license plate was not maintained in a condition to be clearly legible. The distance from which an officer observed the license plate may be relevant… but it is not a controlling legal standard.”
  This is the new governing test that replaces the Unrau “safe following distance” approach.
• “Kansas courts and law enforcement do not have jurisdiction to enforce the penal laws of other states.”
  This clarifies that Kansas law governs Kansas stops, even when the vehicle is registered elsewhere.

What the Court Did Not Decide

• It did not define the precise contours of “foreign materials,” “clearly visible,” or “clearly legible,” beyond explaining that the state name is not among the items Kansas law requires to be legible on the plate face.
• It did not decide whether the dog sniff, consent, or other events post-stop purge the taint of an unconstitutional stop; those exclusionary-rule questions are left to the district court on remand.
• It did not decide whether Illinois’s own plate-display requirements matter in Kansas enforcement—indeed, it held they do not.

Practice Pointers

• For defense counsel: Scrutinize the basis for any plate-stop. If the only articulated reason is that a frame covered the state name, file to suppress under Beck. Develop the record on the legibility of the alphanumeric characters and the decal at the time and place of observation.
• For prosecutors: Train officers to articulate specific, objective facts about the legibility of required information and the conditions affecting it. Be prepared to litigate exclusionary-rule exceptions if the initial stop rationale is inadequate under Beck.
• For law enforcement: Document, photograph/video if possible, the condition of plates at the time of stop, focusing on required identifiers (alphanumeric and decal) and the factors affecting legibility. Avoid reliance on distance-based heuristics alone.
• For motorists and dealers: Plate frames that obscure the printed state name are not, by themselves, unlawful in Kansas. However, any accessory or debris that makes the alphanumeric characters or the registration decal not clearly legible can justify a stop.

Procedural Note on the Modified Opinion

This is a modified opinion. The Reporter’s Note indicates the court granted the Appellee’s motion for rehearing or modification and made changes at slip op. pages 1, 11, and 12. The modifications crystallize the core holdings summarized in the Syllabus: adherence to plain text and the explicit statement that Kansas does not require display of the state name on license plates, except on registration decals.

Conclusion

State v. Beck resets Kansas law on license-plate stops to the statutory text. The Supreme Court firmly holds that the Kansas display statutes do not require the issuing state’s name to be visible on the face of a license plate and rejects the “safe following distance” test that had crept into practice through federal district court decisions. Going forward, the constitutionality of plate-based stops turns on whether, under an objective totality-of-the-circumstances assessment, the plate was “maintained free from foreign materials and in a condition to be clearly legible”—with legibility focused on the alphanumeric characters and registration decal required by Kansas law.

The decision limits a common predicate for traffic stops, narrows opportunities for pretextual enforcement based on plate frames, and realigns suppression analysis with statutory text and standard Fourth Amendment principles. It also signals to the Legislature that any expansion of plate-display requirements—such as a mandate that state names be visible—must be enacted expressly, not inferred by courts. In the broader legal context, Beck exemplifies disciplined textualism and careful calibration of police authority against statutory limits and constitutional safeguards.