State v. Bonds, 299 P.3d 663

Santorio Bonds appeals his felony no-contact order violation conviction after a warrantless traffic stop of a car he rode in.
Officers stopped the car based on reasonable suspicion that the registered owner lied about title transfer and that Bonds, a passenger, had an active arrest warrant.
A prior license-plate check showed a vehicle sold tag, indicating potential failure to transfer title, a misdemeanor continuing offense.
Frisbie identified Bonds as the passenger; Caber confirmed Bonds’s identity and Bonds’s DOC warrant and no-contact order prohibition.
Caber conducted a pocket search incident to Bonds’s arrest after Bonds claimed no identification; Bonds challenges suppression on appeal.
Trial court denied suppression; Bonds was convicted by jury; on appeal, issues include stop legality, pretext, pocket-search legality, and preservation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop justified by reasonable suspicion?	Bonds contends no reasonable suspicion existed.	State argues combined title-offense presence and passenger with warrant justified the stop.	Yes; stop justified by specific, articulable facts.
Does failure to transfer title create a continuing offense justifying the stop?	Bonds argues title-failure was not arrestable; stop thus invalid.	State asserts continuing offense under amended statute supported presence-based stop.	Yes; continuing misdemeanor justified the stop.
Was the stop pretextual?	Stop served as pretext to identify Bonds rather than enforce title law.	Two legitimate, independent purposes supported the stop; pretext analysis not applicable.	No; not a pretextual stop.
Was the pocket search incident to arrest unlawfully conducted and preserved?	Search of Bonds’s pockets violated the Fourth Amendment and was not preserved.	Search incident to arrest was lawful; Jordan controls; issue preserved for review.	Lawful pocket-search incident to arrest; issue not preserved for review.

State v. Ladson, 138 Wn.2d 343 (1999) (traffic stops justified by reasonable suspicion)
State v. Acrey, 148 Wn.2d 738 (2003) (totality-of-circumstances for investigative detentions)
State v. Hendrickson, 129 Wn.2d 61 (1996) ( Fourth Amendment and article I, §7 warrant exceptions)
State v. Williams, 171 Wn.2d 474 (2011) (investigative detentions under article I, §7)
State v. Garvin, 166 Wn.2d 242 (2009) (standard for reviewing suppression rulings)
State v. Jordan, 92 Wn. App. 25 (1998) (searches of arrestee’s person allowed incident to arrest)
United States v. Robinson, 414 U.S. 218 (1973) (scope of searches incident to arrest)
Chimel v. California, 395 U.S. 752 (1969) (grounds for searches incident to arrest)
Arizona v. Gant, 556 U.S. 332 (2009) (car searches post-arrest; not applicable here)
State v. Valdez, 167 Wn.2d 761 (2009) (article I, §7 and Chimel principles)
State v. Phillips, 126 Wn.App. 584 (2005) (vehicle stopped to investigate title transfer status)
State v. MacDicken, 171 Wn. App. 169 (2012) (handcuffed arrestees' access to weapons; pocket-search context)
United States v. Hensley, 469 U.S. 221 (1985) (investigative detention for past crimes may be allowed)