Davis v. State, 322 Ga. App. 217

Davis was a passenger in a vehicle stopped on I-75 in Henry County for failure to maintain lane.
Officer detected odor of alcohol from the driver and had her exit to check impairment.
Officer issued a warning to the driver and ran license information through dispatch to verify validity and warrants.
While waiting for dispatch, officer questioned the two passengers and attempted to run warrant checks; Davis provided his name, rear passenger refused.
The officer, after approaching the rear passenger, smelled burnt marijuana and then received dispatch results; a warrant check and search followed, yielding less than an ounce of marijuana which Davis admitted belonged to him.
Davis moved to suppress the marijuana as the product of an unlawful detention, the matter proceeded to a stipulated bench trial, and he was convicted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the detention was impermissibly extended.	Davis contends questioning after the stop extended detention.	State argues questions were within scope and time of stop.	No impermissible extension; questioning within time to complete warrant check.

Humphreys v. State, 304 Ga. App. 365 (Ga. App. 2010) (standard for reviewing suppression orders)
Rocha v. State, 317 Ga. App. 863 (Ga. App. 2012) (clarifies stop duration and questioning scope)
Chang v. State, 270 Ga. App. 814 (Ga. App. 2004) (permits identification checks and warrant checks as minimally intrusive)
Salmeron v. State, 280 Ga. 735 (Ga. 2006) (watch for prolonging beyond mission; guidance on stop duration)
Proctor v. State, 298 Ga. App. 388 (Ga. App. 2009) (notes on scope of detention during traffic stops)
Young v. State, 310 Ga. App. 270 (Ga. App. 2011) (case on stop duration and reasonable suspicion)
State v. Brown, 278 Ga. App. 457 (Ga. App. 2006) (on warrant checks as minimally intrusive)