State v. Martinez
2017 UT 26
| Utah | 2017Background
- Trooper Horne stopped a car for an improper lane change; George M. Martinez was a passenger.
- Horne asked both driver and Martinez for identification; he entered both license numbers into his in-car database and received results "immediately."
- Within two to three minutes of the stop, Horne learned Martinez had an outstanding arrest warrant, arrested him, and recovered a glass pipe with methamphetamine residue after Martinez admitted possession.
- Martinez moved to suppress the evidence, arguing the trooper violated the Fourth Amendment by asking for his ID and running a warrant check without reasonable suspicion.
- The district court granted suppression, concluding investigation of the passenger without reasonable suspicion exceeded the permissible scope of a routine traffic stop.
- The State appealed; the Utah Supreme Court reversed, holding officer safety justified the brief, voluntary ID request and the negligibly burdensome background check.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an officer may ask a passenger for ID and run a background/warrants check during a routine traffic stop absent reasonable suspicion | Martinez: Asking for ID and running a warrants check (absent reasonable suspicion) unlawfully expands the stop and violates the Fourth Amendment | State: Officer may request passenger ID and run checks as a negligibly burdensome officer-safety measure so long as it does not unreasonably extend the stop | The Court held: Yes — asking for ID and running a background check is permissible for officer safety and did not unreasonably prolong this stop (seconds-long delay) |
Key Cases Cited
- Florida v. Jimeno, 500 U.S. 248 (Fourth Amendment reasonableness framework)
- Terry v. Ohio, 392 U.S. 1 (stop-and-frisk standard; reasonable suspicion requirement)
- United States v. Sharpe, 470 U.S. 675 (scope/duration test for seizures)
- Illinois v. Caballes, 543 U.S. 405 (traffic stop may not be prolonged unreasonably)
- Rodriguez v. United States, 575 U.S. 348 (stop "mission" includes related safety inquiries; extensions must be reasonable)
- Maryland v. Wilson, 519 U.S. 408 (officer safety justifies ordering passengers out of vehicle)
- Pennsylvania v. Mimms, 434 U.S. 106 (officer safety weighty interest during traffic stops)
- Muehler v. Mena, 544 U.S. 93 (mere questioning and requests for identification can be voluntary; no reasonable suspicion required)
- Florida v. Bostick, 501 U.S. 429 (voluntary cooperation doctrine)
- State v. Johnson, 805 P.2d 761 (Utah precedent discussed; not inconsistent with safety-based rule)
- State v. Hansen, 837 P.2d 987 (Utah case on limits of post-stop detention under Terry)
- State v. Chism, 107 P.3d 706 (Utah Ct. App. case addressing reasonable suspicion issues)
