Seatbelt stop was objectively reasonable, so investigatory motive was irrelevant

Seatbelt stop was objectively reasonable, and it did not matter that the officer had an investigatory motive, so the plain view was proper. State v. Sheffield, 2007 Tenn. Crim. App. LEXIS 483 (June 21, 2007):

The state seatbelt law requires a driver and passengers to wear safety belts when a vehicle is in forward motion. See T.C.A. § 55-9-603(a)(1). Thus, upon seeing Defendant driving the car without wearing his seatbelt, Office Hagler had probable cause to believe that Defendant was in violation of the state seatbelt law. It is of no consequence that Officer Hagler had no intention to cite Defendant for violation of the seatbelt law. Likewise, it does not matter that Officer Hagler primarily wanted to investigate the suspicious conduct by Defendant and his passenger. The officer’s initial observation that Defendant was not wearing his seatbelt was sufficient justification for the stop. Once the stop was made, the officer’s detention of Defendant was not unreasonable in light of the sequence of events which occurred. The observation of evidence of contraband in plain view in the vehicle justified a search of the interior of the vehicle, State v. Byerley, 635 S.W.2d 511, 513-14 (Tenn. 1982), a search of the trunk of the vehicle, United States v. Ross, 456 U.S. 798, 820-21,102 S. Ct. 2157, 2170-71, 72 L. Ed. 2d 572 (1982), State v. McCall, 698 S.W.2d 643, 649 (Tenn. Crim. App. 1985), and a search of Defendant’s person and seizure of the evidence discovered as a result of the search of his person. State v. Crutcher, 989 S.W.2d 295, 300 (Tenn. 1999); Rawlings v. Kentucky, 448 U.S. 98, 111, 100 S. Ct. 2556, 2564, 65 L. Ed. 2d 633 (1980). Accordingly, the trial court did not err in denying Defendant’s motion to suppress.

Informant was corroborated by officer going to defendant’s premises and smelling burnt marijuana himself. That made PC. United States v. Walter, 2007 U.S. Dist. LEXIS 44975 (D. Vt. June 20, 2007).*