Unobscured Interpretation: No Traffic Stops for Illegible State Name

State v. Beck, No. 126,350 (Kan. Oct 10, 2025).

Staff Editor William Mitchelson

October 20, 2025

Issue:  Does partial obstruction of the state name on a license plate violate Kan. Stat. Ann. § 8-133 and, consequently, furnish reasonable suspicion to execute a traffic stop?

Answer:  No, partial obstruction of the state name on a license plate does not violate Kan. Stat. Ann. § 8-133 and, therefore, does not justify a traffic stop.

Facts:  On March 2, 2021, Brian Beck was driving on Interstate 70 in Kansas.  The state name on his license plate was partially obstructed by a frame.  He was committing no other traffic infractions.  Sheriff's deputy Bradley Rose executed a traffic stop premised on the name obstruction.  During the traffic stop, Deputy Rose observed that Beck was nervous.  Beck also made suspicious statements about his intended destination.  Rose called for K-9 support.  The narcotics K-9 alerted on Beck’s vehicle.  Beck consented to a search.  That search turned up 2.13 pounds of methamphetamine.

Beck was charged with possession with intent to distribute.  He filed a motion to suppress the evidence obtained in the vehicle search, arguing that the deputy lacked reasonable suspicion to conduct the predicate traffic stop.  The trial court denied that motion.  Beck was convicted.  The Kansas Court of Appeals affirmed the conviction.  The Kansas Supreme Court granted review on a single issue—interpretation of the Kansas license plate display statute.

Discussion:  The Kansas Supreme Court primarily evaluated the language of Kan. Stat. Ann. § 8-133, which governs the display of vehicle license plates, finding no mention of state name anywhere in its text.  The court determined “no Kansas statute requires that a state name must be visible on a license plate except for the information that can be determined from the registration decal.”

Turning to the facts surrounding Beck’s stop, the court reasoned that because there is no requirement that the state name be clearly legible, the partial obstruction of the state name on Beck’s license plate was not a statutory violation.  The court held that since an illegible state name does not violate Kansas law, it cannot furnish reasonable suspicion for a traffic stop.  The Kansas Supreme Court reversed the Court of Appeals' decision that had affirmed the district court's denial of Beck's motion to suppress.

Key Authorities:

Kan. Stat. Ann. § 8-133 (2021) (outlining vehicle license plate display requirements); State v. Jones, 333 P.3d 886 (2014) (explaining constitutional seizure requires reasonable suspicion that seized individual is committing, has committed, or is about to commit a crime or traffic infraction).