Brendlin v. California
Headline: Traffic stops also seize passengers, the Court ruled, allowing passengers to challenge and possibly suppress evidence from unconstitutional stops and affecting how police handle routine traffic stops.
Holding: When police make a traffic stop, a passenger is seized for Fourth Amendment purposes and may challenge the stop’s constitutionality and seek suppression of evidence obtained from it.
- Allows passengers to challenge traffic stops and seek suppression of evidence.
- Limits police reliance on stops that lack reasonable suspicion.
- Police may still order occupants out for safety during lawful stops.
Summary
Background
A deputy pulled over a car to check its registration. The driver was Karen Simeroth and the front-seat passenger was Bruce Brendlin, whom the deputy recognized. After verifying Brendlin had an outstanding parole warrant, officers arrested him and searched him, the driver, and the car, finding drug-related items. Brendlin moved to suppress the evidence, arguing the traffic stop was unlawful because officers lacked reasonable suspicion. State courts split before the matter reached the U.S. Supreme Court.
Reasoning
The central question was whether a passenger is "seized" (detained) when police stop a car and therefore can challenge the stop under the Fourth Amendment (protection against unreasonable searches and seizures). Applying the familiar "reasonable person" test, the Court held that a passenger would not feel free to leave when the police stop the vehicle, so the passenger is seized. The Court rejected the California court’s focus on the officers’ subjective motive or the passenger’s ability to signal submission while the car was moving, and it emphasized officer safety and existing rulings about controlling occupants during stops.
Real world impact
The decision means passengers can challenge the legality of traffic stops and seek suppression of evidence obtained from unlawful stops. Police still may take safety measures, like ordering occupants out during lawful stops. The Supreme Court vacated the California judgment and sent the case back for further consideration, so state courts must address remaining issues.
Dissents or concurrances
The U.S. Supreme Court decision was unanimous. A dissent in the California Supreme Court had argued passengers are detained for officer safety, but the high Court rejected that narrow approach.
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