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State v. Martinez
2017 UT 43
Utah
2017
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Martinez
Court Name: Utah Supreme Court
Date Published: Aug 2, 2017
Citation: 2017 UT 43
Docket Number: Case No. 20141043
Court Abbreviation: Utah