State of Tennessee v. Wayne Donaldson, 380 S.W.3d 86

Traffic stop in Davidson County for failing to stop properly and to signal; officer observed bag of cocaine after Defendant exited vehicle.
Defendant charged with possession with intent to sell/deliver 26+ grams of cocaine within 1,000 feet of a school; motion to suppress denied by trial court.
Appeals court affirmed suppression ruling; Tennessee Supreme Court granted states’ permission to appeal.
Court held Mimms authorizes drivers to exit after a lawful stop for safety, and stop duration must be limited to the stop’s purpose.
Court concluded the stop here was valid, the removal was permissible, and suppression was erroneous; remanded for trial.
Court assessed that credibility findings did not undermine the officer’s sequence of events; stop remained ongoing when Defendant exited the vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether directing Defendant to exit the vehicle after a lawful traffic stop violated Fourth Amendment/Article I, Section 7.	State; Mimms allows officer to require exit for safety.	Donaldson; no safety justification tied to exit, prolongs stop unreasonably.	Yes to valid exit as permissible; not an unlawful seizure.
Whether the duration and manner of the stop were reasonable and within constitutional limits.	State; stop duration was short and within scope.	Donaldson; duration and purpose of questioning extended beyond proper scope.	Stop and brief questioning upheld as reasonable within the circumstances.

Whren v. United States, 517 U.S. 806 (U.S. Supreme Court 1996) (pretextual stops are permissible if based on a legitimate traffic violation)
Mimms v. United States, 434 U.S. 106 (U.S. Supreme Court 1977) (officer safety permits driver to exit after lawful stop)
Vineyard v. State, 958 S.W.2d 730 (Tenn. 1997) (Tennessee constitutional protections coextensive with Fourth Amendment in traffic stops)
Arizona v. Johnson, 555 U.S. 323 (U.S. Supreme Court 2009) (limits on duration and scope of vehicle stops; continued detention standards)
Brignoni-Ponce v. Davis, 422 U.S. 873 (U.S. Supreme Court 1975) (establishes that automobile stops are seizures requiring justification)