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State v. Martinez
2017 UT 26
| Utah | 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Martinez
Court Name: Utah Supreme Court
Date Published: May 2, 2017
Citation: 2017 UT 26
Docket Number: Case No. 20141043
Court Abbreviation: Utah