People v. Cummings, 46 N.E.3d 248

Sterling officer Shane Bland stopped a van because the vehicle was registered to Pearlene Chattic, for whom there was an outstanding arrest warrant.
Bland could not see the driver until after the stop; upon approach he observed the driver was a man (not Chattic).
Bland asked for the driver’s license before explaining the reason for the stop; defendant said he had no license and was cited for driving while suspended.
Trial court granted defendant’s motion to suppress, appellate court affirmed, and this court in Cummings I affirmed, holding the license request impermissibly prolonged the stop after Bland’s reasonable suspicion evaporated.
The U.S. Supreme Court vacated and remanded for reconsideration in light of Rodriguez v. United States, which clarified the scope of “ordinary inquiries” during a traffic stop and forbade prolonging a stop for unrelated investigations absent reasonable suspicion.
On remand, the Illinois Supreme Court held Rodriguez permits ordinary inquiries (including a request for a driver’s license) as part of a stop’s mission for officer safety, reversing the suppression ruling and remanding for further proceedings.

Issue	State's Argument	Cummings' Argument	Held
Whether Officer Bland’s request for the driver’s license after realizing the driver was not the named subject impermissibly prolonged the stop in violation of the Fourth Amendment	License checks are an "ordinary inquiry" incident to any lawful vehicle stop and fall within the stop's mission (including officer safety), so the request did not prolong the stop	Because the stop was solely to locate Chattic (not to enforce traffic laws), checking the driver’s license was not an ordinary inquiry and thus impermissibly extended the detention	A license request is an ordinary inquiry incident to a lawful stop and does not impermissibly prolong the stop; suppression reversed

Illinois v. Cummings, 2014 IL 115769 (Illinois Supreme Court) (earlier decision holding license request impermissibly prolonged the stop)
Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (traffic-stop mission limited to addressing the traffic violation and related safety concerns; unrelated inquiries that measurably extend the stop require reasonable suspicion)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff contemporaneous with stop permissible if it does not extend the stop)
Arizona v. Johnson, 555 U.S. 323 (2009) (unrelated questioning during a stop permissible so long as it does not measurably extend the detention)
City of Indianapolis v. Edmond, 531 U.S. 32 (2000) (distinguishing general criminal investigations from mission-focused traffic-stop inquiries)
Muehler v. Mena, 544 U.S. 93 (2005) (limits on scope and duration of seizures)
United States v. Holt, 264 F.3d 1215 (10th Cir. 2001) (upholding warrant and criminal-history checks during stops as justified by officer safety)