State v. Knight
1 CA-CR 22-0306
| Ariz. Ct. App. | Jul 18, 2024Background
- Defendant Raymond James Knight was a passenger in a rental car stopped for following too closely on Interstate 17 in Yavapai County, Arizona.
- The stop was conducted by an Arizona Department of Public Safety Detective, who observed unusual behavior and nervousness from both driver and Knight during the interaction.
- Rental car paperwork showed neither the driver nor Knight was listed as an authorized user; the car was rented to a third party.
- After issuing a written warning for the traffic violation, officers continued to question the occupants, ultimately using a drug detection dog, which alerted to drugs in the trunk.
- Methamphetamine was found, and Knight was charged with sale/transportation of drugs and possession of paraphernalia.
- Knight moved to suppress evidence, arguing the traffic stop was impermissibly prolonged without reasonable suspicion. The motion was denied, Knight was convicted, and he appealed.
Issues
| Issue | Knight's Argument | State's Argument | Held |
|---|---|---|---|
| Whether the stop was unlawfully prolonged | Detective lacked reasonable suspicion to extend stop | Totality of circumstances gave rise to reasonable suspicion | Stop was lawfully extended based on reasonable suspicion |
| Whether nervousness alone justifies extension | Officer relied mainly on nervousness (which is insufficient) | Nervousness was only one of multiple factors considered | Nervousness not sole factor; other facts supported extension |
| Whether third-party rental status was enough | Being unlisted driver is common, not alone suspicious | Rental by absent third party is a known trafficking indicator | Third-party rental tipped the scale for reasonable suspicion |
| Application of Sweeney and Magner | Facts are analogous and should lead to suppression | Totality differs; court relied on more than Sweeney/Magner | Court properly relied on all factors, not just profiles |
Key Cases Cited
- Arizona v. Johnson, 555 U.S. 323 (2009) (sets scope of permissible activities during a traffic stop)
- Rodriguez v. United States, 575 U.S. 348 (2015) (officer’s authority ends when tasks tied to stop are completed)
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes framework for reasonable suspicion and continued detention)
- Ornelas v. United States, 517 U.S. 690 (1996) (reasonable suspicion judged by totality of circumstances)