The Tenth Circuit found the stop improper:
It might be argued that Officer Riley had reasonable suspicion to stop Mr. Laughrin based not on his criminal history of driving without a valid license, but on the ongoing violation of driving without a valid license--that Mr. Laughrin was still engaged in the same offense that he had been stopped for before. But whether it is reasonable to believe that Mr. Laughrin has continued to drive without a license depends on the length of time since he was last found to be driving without a license. Other circuits have upheld stops for driving without a license based on the officer's knowledge that the motorist had no valid license a week before, United States v. Hope, 906 F.2d 254, 258 (7th Cir. 1990), or 22 days earlier, United States v. Sandridge, 385 F.3d 1032, 1036 (6th Cir. 2004). Twenty-two days is significantly less than 22 weeks. Had Officer Riley testified to the length of the prior suspension, we might be able to affirm the district court's determination that he had reasonable suspicion. Otherwise, however, Officer Riley's information was too stale to justify stopping Mr. Laughrin on the belief that a suspension was still in effect.Good analysis.