State v. Brown, 931 N.W.2d 890

In the early morning, Officer Deering stopped Brown for a traffic violation (failure to stop properly) and observed Brown was unbelted; Deering wrote a warning.
During the stop Deering learned the vehicle was a rental, the location/time were suspicious (dead-end road at 2:44 a.m.), and Brown gave inconsistent statements about where he’d been and lacked details about his stated purpose.
Deering ran Brown’s record and discovered prior drug and violent convictions; two other officers arrived as safety backups.
Before returning Brown’s license and the written warning, Deering asked Brown to exit the vehicle, walked him to the squad car, asked if he had anything (weapons/drugs), and requested consent to search; Deering testified Brown consented, Brown denied consenting.
Deering searched Brown and found multiple bags of crack cocaine and cash; Brown moved to suppress evidence arguing the officer unlawfully extended the stop after completing the traffic-warning task.
The circuit court denied suppression; Brown pled no contest and appealed the denial of his motion to suppress as to the alleged unlawful extension.

Issue	Brown's Argument	State's Argument	Held
Whether asking Brown to exit and requesting consent to search unlawfully extended a completed traffic stop	These requests occurred after the officer had finished writing the warning and thus impermissibly prolonged the stop without reasonable suspicion	The exit order and request for consent fell within the traffic-stop "mission" (officer safety and ordinary inquiries) and did not extend the stop	The court held the requests were part of the stop's mission and did not violate the Fourth Amendment; suppression denied

State v. Floyd, 377 Wis.2d 394, 898 N.W.2d 560 (Wis. 2017) (holding officer safety questions and permission to frisk can be part of a traffic stop's mission)
State v. Wright, 386 Wis.2d 495, 926 N.W.2d 157 (Wis. 2019) (affirming that certain safety-related inquiries fall within the stop mission and need not be treated as an extension)
Rodriguez v. United States, 575 U.S. 348 (U.S. 2015) (limiting prolongation of traffic stops beyond mission unless supported by reasonable suspicion)
Whren v. United States, 517 U.S. 806 (U.S. 1996) (an officer's subjective intent is irrelevant to Fourth Amendment reasonableness)
Pennsylvania v. Mimms, 434 U.S. 106 (U.S. 1977) (permitting officer to order driver out of vehicle as a de minimis intrusion justified by officer safety)
State v. Smith, 379 Wis.2d 86, 905 N.W.2d 353 (Wis. 2018) (discussing tasks incident to traffic stops and safety measures)
State v. Guzy, 139 Wis.2d 663, 407 N.W.2d 548 (Wis. 1987) (recognizing traffic stops as seizures under the Fourth Amendment)