The stop had not concluded, and it wasn’t unreasonably extended by the officer. Criminal history checks are reasonable. “Accordingly, the officer may take reasonable steps to ascertain whether the persons with whom he is dealing might be dangerous. To this end, courts throughout the country have held that an officer generally may reasonably inquire about the identities of persons detained at the scene of a traffic stop and take reasonable steps to quickly verify their identities and to check their criminal histories and for warrants.” Carlisle v. Commonwealth, 2020 Ky. LEXIS 177 (May 28, 2020).
“The Court finds that it reasonably appeared to Officers Colyer and Kirstein that Greene was possibly unconscious and/or in need of medical attention, and the intrusion into his privacy of opening the car door was reasonable under those circumstances.” United States v. Greene, 2020 U.S. Dist. LEXIS 92467 (E.D. Ky. Apr. 20, 2020), adopted, 2020 U.S. Dist. LEXIS 91788 (E.D. Ky. May 27, 2020).*