United States v. Martin, 395 F.Supp.3d 756

On Oct. 12, 2018 Officer Tyler Dawson stopped a car at ~1:36 a.m. for a defective brake light; Jason Buzzard was driver and Paul Martin was front-seat passenger.
Officer observed Martin behaving nervously and knew Martin from prior encounters and as having a history of drug addiction and prior felonies; the stop occurred in an area the officer described as high-crime.
Dawson asked the driver (either immediately or while waiting for routine checks) a single question: “Is there anything illegal in the vehicle?”
Buzzard produced marijuana; Martin admitted possession of a syringe; a subsequent search revealed two firearms hidden under the seats; both were arrested and Buzzard’s phone was seized.
Martin moved to suppress the contraband, arguing the officer’s question was unrelated to the traffic-stop mission and unlawfully prolonged the stop, requiring reasonable suspicion or consent.
The court held an evidentiary hearing, credited aspects of the officer’s testimony, and denied the motion to suppress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether asking “Anything illegal in the vehicle?” was within scope of traffic stop	Officer’s question served officer safety and routine stop purposes	Martin: question was unrelated to traffic mission and exceeded scope	Held: question related to officer safety and ordinary inquiries incident to stop; within scope
Whether the question unlawfully prolonged the stop	Government: single, noninvasive question occurred concurrently with other stop tasks and did not lengthen detention	Martin: even a brief unrelated inquiry required reasonable suspicion because it extended the stop	Held: question did not measurably prolong detention; no unlawful extension and no reasonable suspicion required
Whether contraband found after question must be suppressed	N/A (government defended admissibility)	Martin: evidence flowed from unconstitutional prolongation/question and should be excluded	Held: suppression denied; question constitutional so evidence admissible
Whether question initiated a new investigation into other crimes	Government: a general safety question is incidental and does not start a separate criminal investigation	Martin: asking about illegal items pursued unrelated criminal investigation	Held: court found the single broad question did not begin a new, separate investigation

Rodriguez v. United States, 575 U.S. 348 (2015) (distinguishes permissible stop-related inquiries and limits on extending a stop for unrelated investigations)
Arizona v. Johnson, 555 U.S. 323 (2009) (officer safety considerations may justify certain measures during a traffic stop)
Illinois v. Caballes, 543 U.S. 405 (2005) (limits on unrelated investigative techniques that extend a stop)
Terry v. Ohio, 392 U.S. 1 (1968) (framework for stop-and-frisk and assessing the reasonableness of seizures)
Pennsylvania v. Mimms, 434 U.S. 106 (1977) (permitting ordering occupants out of vehicle for officer safety)
Maryland v. Wilson, 519 U.S. 408 (1997) (extending Mimms to passengers)
United States v. Bowman, 884 F.3d 200 (4th Cir. 2018) (police may ask occupants questions unrelated to traffic infractions during a stop)
United States v. Green, 740 F.3d 275 (4th Cir. 2014) (brief unrelated questioning during background checks did not exceed scope)
United States v. Everett, 601 F.3d 484 (6th Cir. 2010) (officers may ask whether occupants have weapons)
Hudson v. Michigan, 547 U.S. 586 (2006) (exclusionary rule is a last resort)