Whether Glover's owner-driver inference constitutes probable cause to arrest a vehicle's owner for a crime involving the vehicle, even if the police cannot identify the owner as the driver

QUESTION PRESENTED FOR REVIEW This case concerns the scope of Kansas v. Glover, __ U.S. __ 140 S. Ct. 1183, 1188-89, 91 (2020), which held that it is reasonable for an officer to infer that a person seen driving a vehicle is its registered owner, and that this inference provides reasonable suspicion to initiate a traffic stop if the owner’s license is revoked. Dicta from Glover (i.e., the officer therein had “more than reasonable suspicion”) has left lower courts confused and divided over whether, and in what circumstances, Glover’s owner-driver inference provides probable cause to arrest a vehicle’s registered owner. Glover, 140 S.Ct. at 1188. While lower courts generally consistently apply Glover in traffic-stop cases, they interpret it inconsistently and differently in cases like the instant one, where the police have reason to believe that a car was involved in a crime (e.g. fleeing the police) but the unidentified driver got away. Here, the Illinois Appellate Court held that the police had probable cause to arrest LaDerrius Williams for fleeing/eluding the police pursuant to Glover simply because he owned the fleeing vehicle, even though the driver got away and the police admittedly could not identify Williams as the offending driver. People v. Williams, 2023 IL App (4th) 220481-U, 418 (citing Glover, 140 S.Ct. at 1188). See also State v. Young, 953 N.W.2d 100 (Wisc. App. 2020) (same). But see Caskey v. Fenton, No. 22-3100, 2022 WL 16964963 (6th Cir. 2022) (finding that Glover’s owner-driver inference did not alone give the police probable cause to arrest the car’s owner for fleeing the police where the police could not identify the owner as the driver); Groce v. Jackson, 2022 WL 3645906 (N.C. 2022) (similar); Pennsylvania v. Hutchinson, 2023 WL 8453141 at *6 (Pa. Super. Ct. i 2023) (Glover’s owner-driver inference gave the police reasonable suspicion to believe that the car’s registered owner was the unidentified motorist who fled the police). The question thus presented is whether Glover’s owner-driver inference constitutes, not only reasonable suspicion to initiate a traffic stop of a motorist if the police have reason to believe the vehicle’s owner committed a crime, but also probable cause to arrest a vehicle’s owner at any time if the police have reason to believe his car was involved in a crime, even if the police could not identify the vehicle’s owner as the driver who committed the crime? ii