State v. Martinez
2017 UT 43
Utah2017Background
- Trooper Jeremy Horne stopped a car for an improper lane change; George M. Martinez was a passenger.
- Horne asked both the driver and Martinez for identification; he returned to his patrol car and ran records checks on both via in‑car computer.
- After entering the driver’s license numbers, Horne received the driver’s results and "immediately" received Martinez’s results, learning Martinez had an outstanding arrest warrant.
- Horne arrested Martinez about two to three minutes after the stop; Martinez produced a glass pipe that tested positive for methamphetamine residue.
- Martinez moved to suppress the evidence, arguing the officer violated the Fourth Amendment by requesting his ID and running a warrant check without reasonable suspicion; the district court granted suppression.
- The State appealed; the Utah Supreme Court reversed, holding officer safety justified the brief, voluntary inquiry and the seconds‑long records check did not unreasonably prolong the stop.
Issues
| Issue | Martinez's Argument | State's Argument | Held |
|---|---|---|---|
| Whether an officer may ask a passenger for ID and run a background/warrant check without reasonable suspicion | Such requests are investigative detentions beyond a traffic stop’s scope and require reasonable suspicion; evidence from the check must be suppressed | Officers may ask passengers for ID and run background checks as a routine, minimally burdensome officer‑safety measure so long as it does not unreasonably extend the stop | Permissible: officer may request passenger ID and run a background check without reasonable suspicion when voluntary and not unduly prolonging the stop |
| Whether the records check here unreasonably prolonged the traffic stop | The check impermissibly extended the stop beyond its mission | The records check took only seconds and did not measurably extend the stop | Held not unreasonably prolonged: the inquiry lasted ~1–5 seconds and fell within permissible, negligibly burdensome safety measures |
| Whether voluntariness of compliance matters | The interaction was effectively a further seizure unless justified by suspicion | The exchange was voluntary (Martinez supplied his ID) and mere questioning is not a seizure | Court treated the ID production as voluntary and not a Fourth Amendment seizure requiring suspicion |
| Whether prior Utah cases compel a different result | Argued Johnson, Hansen, Chism require reasonable suspicion for additional inquiries | Those cases addressed reasonable suspicion under Terry and did not consider negligibly burdensome safety checks; they do not control here | Court declined to overrule prior cases and distinguished them; allowed limited safety‑based inquiries consistent with U.S. Supreme Court precedent |
Key Cases Cited
- Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (limits on prolonging traffic stops; stop mission includes safety concerns)
- Florida v. Jimeno, 500 U.S. 248 (U.S. 1991) (Fourth Amendment reasonableness standard)
- United States v. Sharpe, 470 U.S. 675 (U.S. 1985) (reasonable seizure test)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (stop‑and‑frisk reasonable suspicion framework)
- Illinois v. Caballes, 543 U.S. 405 (U.S. 2005) (traffic stop may not be unreasonably prolonged)
- Maryland v. Wilson, 519 U.S. 408 (U.S. 1997) (order passengers out for officer safety)
- Pennsylvania v. Mimms, 434 U.S. 106 (U.S. 1977) (officer safety justifies certain measures during stops)
- Utah v. Strieff, 136 S. Ct. 2056 (U.S. 2016) (warrant check can be a negligibly burdensome officer‑safety measure)
- Muehler v. Mena, 544 U.S. 93 (U.S. 2005) (mere questioning does not necessarily constitute a seizure)
- Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consensual cooperation not proscribed by Fourth Amendment)
- United States v. Rice, 483 F.3d 1079 (10th Cir. 2007) (officers may ask passengers for ID and run background checks for safety)
- United States v. Chaney, 584 F.3d 20 (1st Cir. 2009) (brief passenger ID inquiries did not measurably extend stop)
- United States v. Jenson, 462 F.3d 399 (5th Cir. 2006) (officer may run checks on occupants)
