State v. Andrew R. Reierson, 2010AP596-CR, District 4, 4/28/11court of appeals decision (1-judge, not for publication); for Reierson: John Smerlinski; case activityThe officer’s erroneous reading of Reierson’s license plate, causing the officer to wrongly believe that his registration had expired, nonetheless supported stop of the car under the good-faith rule.¶11 We conclude the circuit court properly denied the motion to suppress because the officer had probable cause to stop Reierson for operating with an expired registration, contrary to Wis. Stat. § 341.04(1), based on the officer’s reasonable, good-faith mistake of fact in misreading Reierson’s license plate number. The officer testified he misread the last numeral on the plate (mistaking an “8” for a “6”) because the numeral was obscured by a small screw or bolt going through the plate.

And, consistent with the holding in Lord, Jaeger did not initiate an investigatory stop of Reindl-Knaak’s vehicle for the purpose of verifying registration based solely on the display of temporary license plates. SeeLord, 297 Wis. 2d 592, ¶7. Rather, Jaeger initiated the stop based on his confirmation that Reindl-Knaak’s vehicle had an expired registration contrary to Wis. Stat. § 341.04(1). Jaeger did not know at that point that the vehicle was subject to a valid temporary operation plate.The fact that the temporary plate may have been valid didn’t prevent the officer from conducting the stop, given the officer’s “confirmation that, based on the front license plate, the vehicle registration was expired,” ¶14.

” The supreme court suggested, without quite holding, the viability of this rule, in State v. Roosevelt Williams, 2001 WI 21, ¶45 n. 21:The absence of license plates alone can reasonably justify a stop because, without investigation, the police are unable to determine whether the vehicle is stolen or otherwise properly registered. See State v. Griffin, 183 Wis. 2d 327, 329, 515 N.W.2d 535 (Ct. App. 1994); see also Wis. Stat. § 341.04 (prohibits operation of a motor vehicle without registration or pending application for registration); § 341.15(3) (requires display of registration plates).And yet, there may be an argument that a “per se blanket rule” justifying a stop is no more permissible for the lawful omission of a temporary plate than for its display.