State v. Warren, 499 P.3d 423

Boise PD stopped a GMC Yukon for canceled/expired registration; driver Steven Warren and passenger Jennifer Warren identified themselves as husband and wife.
Officer query returned alerts for a civil protection order and a criminal no-contact order involving Steven and Jennifer; officers then abandoned the registration inquiry to investigate possible no-contact violation.
Officers asked Jennifer to exit the vehicle; while waiting for dispatch confirmation about the orders, Jennifer produced a lighter, money, and two syringes from her pockets.
A drug-detection dog alerted on the vehicle; a subsequent search turned up suspected marijuana and hydrocodone in Jennifer’s purse; dispatch later confirmed the criminal no-contact order and Steven was arrested.
Jennifer was arrested; further search of her person produced methamphetamine. She moved to suppress evidence as fruit of an unlawful extension of the traffic stop; the district court granted suppression.
The State appealed; the Idaho Supreme Court reversed, holding the continued detention of the passenger was lawful when reasonable suspicion arose that the driver was committing a more serious crime.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Warren)	Held
Whether officers lawfully continued to detain a passenger after a traffic stop shifted from a registration investigation to investigating a possible no-contact order violation	Reasonable suspicion that the driver was violating protection orders justified extending the stop and detaining all occupants for officer safety and scene control	Once officers abandoned the original traffic-mission, the stop ended; no independent reasonable suspicion tied to Jennifer supported continued detention	Reversed district court: detention was lawful because reasonable suspicion that the driver committed a more serious crime justified continued control of the scene, including detaining the passenger
Whether evidence discovered after the extended detention must be suppressed	Evidence admissible because the extension was supported by reasonable suspicion and concerns for officer safety	Evidence should be suppressed as fruit of unlawful detention absent individualized suspicion of passenger	Court held evidence suppression was erroneous given lawful detention; note concurrence reserved question whether individualized suspicion is required to search a passenger’s person

Arizona v. Johnson, 555 U.S. 323 (passenger detention during a traffic stop remains reasonable for the duration of the stop)
Rodriguez v. United States, 575 U.S. 348 (traffic stop cannot be prolonged beyond mission absent reasonable suspicion)
Brendlin v. California, 551 U.S. 249 (passenger is seized during a traffic stop)
Delaware v. Prouse, 440 U.S. 648 (vehicle stop is a seizure under the Fourth Amendment)
Illinois v. Caballes, 543 U.S. 405 (dog sniff during lawful traffic stop does not violate Fourth Amendment absent extension)
State v. Linze, 161 Idaho 605, 389 P.3d 150 (Idaho case applying Rodriguez to suppress evidence where officer abandoned traffic mission without reasonable suspicion)
United States v. Landeros, 913 F.3d 862 (9th Cir.: extension to question passenger requires that extension be part of mission or supported by independent reasonable suspicion)
Maryland v. Wilson, 519 U.S. 408 (officer safety justifies ordering passengers out of vehicle during stop)
State v. Phipps, 166 Idaho 1, 454 P.3d 1084 (upholding detention of occupants during parole search for officer safety)