WA: Request for proof of payment of a bus fare is not a search

Request for proof of payment of a public transportation fare is not a seizure under the Fourth Amendment or the state constitution. Defendant consented to the terms of ridership by boarding the bus, which included paying the fare and having proof of payment. State v. Meredith, 2021 Wash. App. LEXIS 1798 (July 26, 2021):

By boarding a public bus and accepting transportation, Zachery Meredith consented to the conditions of ridership. Those conditions include paying bus fare and complying with a fare enforcement officer’s request for proof of payment. Even assuming that Meredith was seized when an officer requested that he provide proof of payment, the officer’s request remained within the scope of Meredith’s consent. Because Meredith consented to the conditions of ridership and failed to provide proof of payment when requested, the trial court did not err by denying Meredith’s motion to suppress evidence gathered by the officer conducting fare enforcement.

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