MN: Driver’s potential violation of a pretrial release condition justified extending stop

The driver’s potential violation of a pretrial release condition observed by the officer was sufficient justification for extending a traffic stop first based on failure to signal. Violation of a condition of release could be a criminal violation. State v. Sargent, 2020 Minn. App. LEXIS 270 (Sept. 28, 2020).

“Clark argues that, when the officer blocked his path of exit with the police vehicle, he was ‘seized,’ thereby implicating the Fourth Amendment. This Court has reviewed the video footage, and observed such things as the positions of the vehicles and the curb, and the numbers of steps taken by the officer to walk from the curb and to the police vehicle, and finds the police vehicle did not block Clark’s vehicle and there was enough space for Clark to exit the parking space. Thus, the Fourth Amendment was not implicated at the moment the police vehicle came to rest and/or before the officer became aware of any contraband.” United States v. Clark, 2020 U.S. Dist. LEXIS 177300 (M.D. Ala. Sept. 28, 2020).*