People v. Simmons, 316 Mich. App. 322

On Dec 14, 2014 Officer Robert Cavett stopped a car because there was no metal license plate on the rear; a paper temporary plate was visible in the rear window but its characters were illegible from Cavett’s approach.
Cavett approached to within 3–4 feet, could not read the temporary paper plate (writing was "dim"), and testified he did not examine it further for safety reasons though he admitted it would have taken about five seconds to verify.
Defendant produced a state ID but not a driver’s license or vehicle registration; a LEIN/ computer check showed defendant’s license was suspended, and he was arrested for driving with a suspended license.
After the owner (a passenger) consented, Cavett searched the vehicle and found firearms and ammunition; defendant was charged with weapons and related offenses and the suspended-license offense.
Defendant moved to suppress evidence, arguing the stop and seizure became unlawful because the officer could have verified the temporary plate in seconds; the trial court granted suppression.
The prosecution appealed; the Court of Appeals reversed, holding the initial stop and subsequent detention were reasonable and lawful under the Fourth Amendment and Michigan law.

Issue	People’s Argument	Simmons’s Argument	Held
Was the traffic stop justified?	Stop lawful: officer had reasonable suspicion because no readable metal plate was displayed.	Stop unlawful: officer should have verified the temporary paper plate before detaining.	Stop justified: unreadable plate supported a violation of MCL 257.225 and reasonable suspicion to stop.
Was detention reasonably related in scope?	Questions about license/registration and running LEIN were routine and tied to the stop.	Detention exceeded scope because officer could have spent five seconds to verify temporary tag.	Detention reasonable: asking for ID/registration and running a computer check were appropriate.
Did failure to read temporary plate render the stop unconstitutional?	No—plate was not in a clearly visible or legible condition; closer inspection would not cure the statutory violation.	Yes—brief verification would have shown a valid temporary plate, negating the basis for further detention.	No—because the plate was not legible or clearly visible, officer’s conduct remained lawful.
Should evidence from subsequent vehicle search be suppressed?	Evidence admissible because arrest and search followed a lawful stop and routine checks/consent.	Evidence should be suppressed as fruit of an unlawful seizure.	Evidence not suppressed at appellate level: underlying stop/detention lawful, so search/consent-based discovery stands for further proceedings.

People v. Davis, 250 Mich. App. 357 (Mich. Ct. App.) (discussing traffic-stop grounds and LEIN checks)
People v. Williams, 472 Mich. 308 (Mich.) (standard for reasonableness of traffic-stop scope)
Terry v. Ohio, 392 U.S. 1 (U.S.) (framework for justifying seizures and scope under Fourth Amendment)
People v. Williams, 236 Mich. App. 610 (Mich. Ct. App.) (traffic stop constitutes a seizure; reasonable suspicion standard)
People v. Dunbar, 499 Mich. 60 (Mich.) (duty to maintain a legible license plate)