ID: Not unreasonable to check wants and warrants on passenger during a traffic stop

“This appeal arises out of a traffic stop where a single officer, without having reasonable suspicion that a crime involving the passenger was afoot, checked the passenger for outstanding warrants. The officer used her patrol vehicle’s computer and received a ‘hit’ for a warrant and arrested the passenger. After the arrest, the officer discovered methamphetamine in the passenger’s purse, the rear of the patrol vehicle where the passenger was seated, and on the passenger’s person. The district court ordered the methamphetamine evidence suppressed after concluding the officer unlawfully extended the traffic stop by checking the passenger for outstanding warrants absent reasonable suspicion or a safety justification particular to that stop. We reverse and remand as the Fourth Amendment permits law enforcement to check passengers for outstanding warrants as a matter of course during traffic stops because of officer safety concerns.” State v. Wharton, 2022 Ida. LEXIS 60 (May 23, 2022).

This inventory followed policy and was otherwise reasonable, despite the investigative motive the police also probably had. State v. Johnson, 2022-Ohio-1733, 2022 Ohio App. LEXIS 1613 (10th Dist. May 24, 2022).

The anticipatory warrant here was lawful, so defense counsel wasn’t ineffective for not challenging it. Gober v. United States, 2022 U.S. Dist. LEXIS 92964 (N.D.Ala. May 24, 2022).*