Arizona Revised Statutes
Ariz. Rev. Stat. § 28-1594 (2026)
Authority to detain persons
✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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A peace officer or duly authorized agent of a traffic enforcement agency may stop and detain a person as is reasonably necessary to investigate an actual or suspected violation of this title and to serve a copy of the traffic complaint for an alleged civil or criminal violation of this title.
Notes of Decisions
Cited in 14
cases (4 in the last 5 years), 2003–2026 · leading case: State v. Box, 73 P.3d 623 (Ariz. Ct. App. 2003).
State v. Box, 73 P.3d 623 (Ariz. Ct. App. 2003). “Stop Authorized by A.R.S. § 28-1594 ¶ 8 Appellant first argues, as he did below, that Baxley was not authorized to stop him because the officer had not personally observed him speeding.”
State v. Sweeney, 227 P.3d 868 (Ariz. Ct. App. 2010). “" A.R.S. § 28-1594 (2004). ¶ 38 Here, the record indicates that Officer Craft observed Appellant travelling .”
State of Arizona v. Francisco Flores Huez, Jr., 380 P.3d 103 (Ariz. Ct. App. 2016). “The court in Box construed two statutes, A.R.S. §§ 28-1594 and 13-3883, to suggest that officers are permitted "to stop a vehicle and detain the driver for an actual or suspected traffic violation not committed in that officer’s presence but observed and reported by another…”
State of Arizona v. Aaron Raymond Fikes, 267 P.3d 1181 (Ariz. Ct. App. 2011). “A.R.S. § 28-1594. However, “[a]n investigatory stop of a vehicle constitutes a seizure under the Fourth Amendment.”
State v. Hernandez, 399 P.3d 115 (Ariz. Ct. App. 2017). “It has concluded that driving without insurance is an offense that requires law enforcement authority to stop a vehicle suspected of lacking insurance, A.R.S. §§ 28-1594, 28-4033; further, refusal to stop for this offense is punishable as a misdemeanor or a felony, A.”
State of Arizona v. Lenny M. Box, No. 2 CA-CR 2001-0491 (Ariz. Ct. App. July 31, 2003). “In rejecting this claim, the trial court found it was permissible for Baxley to stop and temporarily detain appellant at the request of Torres, who had actually seen appellant speeding.”
State v. Paul, No. 1 CA-CR 16-0262 (Ariz. Ct. App. May 23, 2017). “at 464, ¶ 7 ; see also A.R.S. § 28-1594; State v. Teagle, 217 Ariz.”
State v. Witzig, No. 1 CA-CR 17-0006 (Ariz. Ct. App. Dec. 5, 2017). “” Further, under A.R.S. § 28-1594, police may stop and detain a 3 STATE v.”
State v. Dennis, No. 1 CA-CR 17-0495 (Ariz. Ct. App. May 10, 2018). “2009) (finding that reasonable suspicion is sufficient to justify a traffic stop); A.R.S. § 28-1594 (providing that officers "may stop and detain a person as is reasonably necessary to investigate an actual or suspected [traffic] violation").”
State v. Lincourt, No. 1 CA-CR 18-0290 (Ariz. Ct. App. July 25, 2019). “Deputy Watson testified at the suppression hearing that, before stopping Lincourt, his radar indicated she was driving fifty miles per hour in a forty-five mile-per-hour posted speed zone. Deputy Watson also explained that he calibrated the radar before his shift that day, as he…”
State v. Robertson, No. 1 CA-JV 23-0026 (Ariz. Ct. App. June 11, 2024). “, officers received only limited, incomplete, and contradictory information that could not sustain reasonable suspicion as to Robertson’s involvement with the hit-and-run.”
State of Arizona v. Asalia Guadalupe Alvarez-Soto, 579 P.3d 1227 (Ariz. 2025). “The traffic statute at issue in this case, § 28-721(B), states that: On all roadways, a person driving a vehicle proceeding at less than the normal speed of traffic at the time and place and under the conditions then existing shall drive the vehicle in the right-hand lane then…”
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