Ariz. Rev. Stat. » Title 28
Arizona Revised Statutes

Ariz. Rev. Stat. § 28-1594 (2026)

Authority to detain persons

✓ current as of May 2026
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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).
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State v. Box, 73 P.3d 623 (Ariz. Ct. App. 2003). · cites it 9× “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). · cites it 4× “" 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). · cites it 2× “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). · cites it 2× “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). · cites it 2× “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 (Ariz. Ct. App. 2003). · cites it 9× “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 (Ariz. Ct. App. 2017). · cites it 2× “at 464, ¶ 7 ; see also A.R.S. § 28-1594; State v. Teagle, 217 Ariz.”
State v. Witzig (Ariz. Ct. App. 2017). · cites it 2× “” Further, under A.R.S. § 28-1594, police may stop and detain a 3 STATE v.”
State v. Dennis (Ariz. Ct. App. 2018). · cites it 2× “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 (Ariz. Ct. App. 2019). · cites it 2× “¶8 First, Lincourt argues Deputy Watson lacked reasonable suspicion to stop her for speeding.”
State v. Robertson (Ariz. Ct. App. 2024). · cites it 2× “2011) (citing A.R.S. § 28-1594), so long as the officer’s suspicion that the person has committed the traffic violation is “articulable” and “reasonable” State v.”
State of Arizona v. Asalia Guadalupe Alvarez-Soto (Ariz. 2025). · cites it 2× “¶19 We begin our de novo review to determine if the record establishes reasonable suspicion for the traffic stop by considering Shewey’s understanding of the facts and relevant law.”
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