State of Tennessee v. Mechelle L. Montgomery, 462 S.W.3d 482

Dispatch reported a possible unwanted/intoxicated person (Mechelle Montgomery) at a residence on Trinity Road; officers were dispatched—Shoap as lead, Reiman as backup.
Officers located a matching black Ford Mustang with two women in a nearby church parking lot; Reiman parked, did not activate lights, approached, and identified the driver as Montgomery.
Reiman smelled alcohol, observed watery eyes and slightly slurred speech, and took the driver’s license from Montgomery, stating he would “hang out here for a little bit” while waiting for Shoap to return from the residence.
Reiman retained the license for approximately 10–15 minutes; when Shoap returned he conducted field sobriety tests, placed Montgomery in his patrol car, and both officers smelled burnt marijuana in/around the vehicle.
Officers searched the car and found an open alcoholic drink and a hand‑rolled marijuana joint; Montgomery moved to suppress, arguing the detention was unreasonably prolonged.
The trial court granted suppression; the Court of Criminal Appeals affirmed. The Tennessee Supreme Court reversed, holding the brief 10–15 minute wait for the lead officer was reasonable.

Issue	State's Argument	Montgomery's Argument	Held
Whether Reiman’s retention of the driver’s license and 10–15 minute wait constituted an unlawful seizure or an unreasonably prolonged investigatory detention	Waiting for the lead officer (Shoap) while retaining license was reasonable given the call and proximity; brief wait allowed confirmation and safety	The short detention was unlawfully prolonged because Reiman could have immediately investigated (e.g., perform sobriety tests) instead of holding her for Shoap	Held: The seizure occurred when Reiman retained the license, but the 10–15 minute delay was reasonable and did not unreasonably prolong the stop; suppression reversed

Coolidge v. New Hampshire, 403 U.S. 443 (1971) (warrantless searches presumptively unreasonable)
Katz v. United States, 389 U.S. 347 (1967) (Fourth Amendment search/seizure principles)
Terry v. Ohio, 392 U.S. 1 (1968) (investigatory stop requires reasonable suspicion; scope/duration limits)
United States v. Sharpe, 470 U.S. 675 (1985) (brief detention to await another officer can be reasonable)
Michigan v. Long, 463 U.S. 1032 (1983) (vehicle stops pose officer safety risks justifying precautions)
State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (standard of review for suppression findings)
State v. Daniel, 12 S.W.3d 420 (Tenn. 2000) (consensual encounter becomes seizure when liberty restrained)
State v. Simpson, 968 S.W.2d 776 (Tenn. 1998) (detention must be reasonably related in scope/duration)
State v. Troxell, 78 S.W.3d 866 (Tenn. 2002) (detention becomes unreasonable if time/scope exceed proper parameters)
State v. Williamson, 368 S.W.3d 468 (Tenn. 2012) (totality of circumstances for reasonable suspicion)