citation warning (Maryland) · Go Syfert
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citation warning in Maryland

23 Maryland opinions name it 2 courts 1995–2020 0 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Ferris v. Stategreen
md · 1999 · cited in 15 Maryland opinions naming this issue, 2002–2020
2 sentences

2020Brendlin v. California, 551 U.S. 249, 255 (2007) (“everyone in the vehicle” is seized during a lawful investigatory traffic stop).21 The permitted stop of the vehicle (and associated lawful detention of its occupants) allows the police “to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with the intent to issue a citation or warning.” Ferris v. State, 355 Md. 356, 372 (1999).

2019Ordinarily, the purpose of a traffic stop “is to enforce the laws of the roadway, and . . . to investigate the manner of driving with the intent to issue a citation or warning.” Ferris v. State, 355 Md. 356, 372 , 735 A.2d 491, 499 (1999).

615
Florida v. Royergreen
scotus · 1983 · cited in 4 Maryland opinions naming this issue, 2002–2020
2 sentences

2002Florida v. Royer, 460 U.S. 491, 500 , 103 S.Ct. 1319, 1325 , 75 L.Ed.2d 229 (1983), and its progeny teach that a second stop occurs when the officer detains the motorist “longer than is necessary to effectuate the purpose of the [initial] stop.” “[T]he officer’s purpose in an ordinary traffic stop is to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with the intent to issue a citation or warning.

2002Florida v. Royer, 460 U.S. 491, 500 , 103 S.Ct. 1319, 1325 , 75 L.Ed.2d 229 (1983), and its progeny teach that a second stop occurs when the officer detains the motorist “longer than is necessary to effectuate the purpose of the [initial] stop.” “[T]he officer’s purpose in an ordinary traffic stop is to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with the intent to issue a citation or warning.

24
State v. Greengreen
md · 2003 · cited in 6 Maryland opinions naming this issue, 2005–2018
2 sentences

2018See, e.g., Byndloss v. State , 391 Md. 462 , 893 A.2d 1119 (2006) (validating a traffic stop where petitioner was stopped for having her license plate obscured by a plastic license plate cover); State v. Green , 375 Md. 595 , 609, 826 A.2d 486 (2003) (stating that "when a police officer has probable cause to believe that a driver has broken a traffic law, the officer may detain *539 the driver temporarily 'to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with intent to issue a citation or warning' " (quoting Ferris v. State , 355 Md. 356 , 372, 735 A.2d 4

2018See, e.g., Byndloss v. State , 391 Md. 462 , 893 A.2d 1119 (2006) (validating a traffic stop where petitioner was stopped for having her license plate obscured by a plastic license plate cover); State v. Green , 375 Md. 595 , 609, 826 A.2d 486 (2003) (stating that "when a police officer has probable cause to believe that a driver has broken a traffic law, the officer may detain *539 the driver temporarily 'to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with intent to issue a citation or warning' " (quoting Ferris v. State , 355 Md. 356 , 372, 735 A.2d 4

16
Whren v. United Statesgreen
scotus · 1996 · cited in 2 Maryland opinions naming this issue, 2003–2017
2 sentences

2017Although a traffic stop does implicate the Fourth Amendment, no violation occurs when a law enforcement officer has probable cause to believe the vehicle stopped has violated a traffic law and the officer temporarily detains the vehicle “ ‘to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with intent to issue a citation or warning.’ ” State v. Green, 375 Md. 595, 609 , 826 A.2d 486 (2003)(quoting Ferris v. State, 355 Md. 356, 369 , 735 A.2d 491 (1999)(citing Whren v. United States, 517 U.S. 806, 810 , 116 S.Ct. 1769 , 135 L.Ed.2d 89 (1996))).

2017Although a traffic stop does implicate the Fourth Amendment, no violation occurs when a law enforcement officer has probable cause to believe the vehicle stopped has violated a traffic law and the officer temporarily detains the vehicle “ ‘to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with intent to issue a citation or warning.’ ” State v. Green, 375 Md. 595, 609 , 826 A.2d 486 (2003)(quoting Ferris v. State, 355 Md. 356, 369 , 735 A.2d 491 (1999)(citing Whren v. United States, 517 U.S. 806, 810 , 116 S.Ct. 1769 , 135 L.Ed.2d 89 (1996))).

12
Brendlin v. Californiagreen
scotus · 2007 · cited in 1 Maryland opinions naming this issue, 2020–2020
1 sentence

2020Brendlin v. California, 551 U.S. 249, 255 (2007) (“everyone in the vehicle” is seized during a lawful investigatory traffic stop).21 The permitted stop of the vehicle (and associated lawful detention of its occupants) allows the police “to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with the intent to issue a citation or warning.” Ferris v. State, 355 Md. 356, 372 (1999).

11
Byndloss v. Stategreen
md · 2006 · cited in 1 Maryland opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., Byndloss v. State , 391 Md. 462 , 893 A.2d 1119 (2006) (validating a traffic stop where petitioner was stopped for having her license plate obscured by a plastic license plate cover); State v. Green , 375 Md. 595 , 609, 826 A.2d 486 (2003) (stating that "when a police officer has probable cause to believe that a driver has broken a traffic law, the officer may detain *539 the driver temporarily 'to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with intent to issue a citation or warning' " (quoting Ferris v. State , 355 Md. 356 , 372, 735 A.2d 4

2018See, e.g., Byndloss v. State , 391 Md. 462 , 893 A.2d 1119 (2006) (validating a traffic stop where petitioner was stopped for having her license plate obscured by a plastic license plate cover); State v. Green , 375 Md. 595 , 609, 826 A.2d 486 (2003) (stating that "when a police officer has probable cause to believe that a driver has broken a traffic law, the officer may detain *539 the driver temporarily 'to enforce the laws of the roadway, and ordinarily to investigate the manner of driving with intent to issue a citation or warning' " (quoting Ferris v. State , 355 Md. 356 , 372, 735 A.2d 4

11
Delaware v. Prousegreen
scotus · 1979 · cited in 1 Maryland opinions naming this issue, 2002–2002
2 sentences

2002See Delaware v. Prouse, 440 U.S. 648, 663 , 99 S.Ct. 1391, 1401 , 59 L.Ed.2d 660 (1979); Wilkes, 364 Md. at 578, 774 A.2d at 434. [4] In order for the continued detention of Nathan and Shaw to be permissible, therefore, there had to exist reasonable, articulable suspicion of criminal activity sufficient to justify the seizure, and the limits of a Terry stop must not have been exceeded.

2002See Delaware v. Prouse, 440 U.S. 648, 663 , 99 S.Ct. 1391, 1401 , 59 L.Ed.2d 660 (1979); Wilkes, 364 Md. at 578, 774 A.2d at 434. [4] In order for the continued detention of Nathan and Shaw to be permissible, therefore, there had to exist reasonable, articulable suspicion of criminal activity sufficient to justify the seizure, and the limits of a Terry stop must not have been exceeded.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Munafo v. State green
mdctspecapp · 1995
2 sentences

2000With respect to the tactical inefficacy of such a calculated delay in issuing a traffic warning, Judge Davis’s observation in Munafo v. State, 105 Md.App. at 672 , 660 A.2d 1068 , is pertinent: The distinguishing fact in the present case is that Deputy Houck did not actually issue a citation or warning after receiving word that Munafo’s license and rental agreement were valid.

2000With respect to the tactical inefficacy of such a calculated delay in issuing a traffic warning, Judge Davis’s observation in Munafo v. State, 105 Md.App. at 672 , 660 A.2d 1068 , is pertinent: The distinguishing fact in the present case is that Deputy Houck did not actually issue a citation or warning after receiving word that Munafo’s license and rental agreement were valid.

51998–2006
Graham v. State green
mdctspecapp · 1998
2 sentences

2006We have similarly opined that a single detention takes place and a K-9 scan for drugs is constitutionally permissible in situations where the scan is ‘at a point in time when the trooper “was still awaiting the results of the license and registration check [and] the scan did not prolong the detention.’ ” Graham v. State, 119 Md.App. 444, 469 , 705 A.2d 82 [, 94] (1998) (quoting Munafo [v. State], 105 Md.App. [662,] 671-72, 660 A.2d 1068 [, 1072 (1995)]).

2006We have similarly opined that a single detention takes place and a K-9 scan for drugs is constitutionally permissible in situations where the scan is ‘at a point in time when the trooper “was still awaiting the results of the license and registration check [and] the scan did not prolong the detention.’ ” Graham v. State, 119 Md.App. 444, 469 , 705 A.2d 82 [, 94] (1998) (quoting Munafo [v. State], 105 Md.App. [662,] 671-72, 660 A.2d 1068 [, 1072 (1995)]).

22005–2006
Nathan v. State green
md · 2002
2 sentences

2006The Court of Appeals has unequivocally confirmed the principle that ‘[i]t is clear that an officer conducting a routine traffic stop may request a driver’s license, vehicle registration, and insurance papers, run a computer check, and issue a citation or warning.’ Nathan [v. State], 370 Md. [648,] 661-62, 805 A.2d 1086 , [1094 (2002)].

2006The Court of Appeals has unequivocally confirmed the principle that `[i]t is clear that an officer conducting a routine traffic stop may request a driver's license, vehicle registration, and insurance papers, run a computer check, and issue a citation or warning.' Nathan [ v. State ], 370 Md. [648,] 661-62, 805 A.2d 1086 , [1094 (2002)].

22005–2006
Snow v. State green
mdctspecapp · 1990
2 sentences

1997This Court held that the motion to suppress should have been granted, reasoning that in Snow, 84 Md.App. at 248 , 578 A.2d 816 , we concluded that the purpose of the traffic stop is to issue a citation or warning.

1997This Court held that the motion to suppress should have been granted, reasoning that in Snow, 84 Md.App. at 248 , 578 A.2d 816 , we concluded that the purpose of the traffic stop is to issue a citation or warning.

21995–1997
Lewis v. State green
md · 2007
2 sentences

2018Steck not only urges this Court to find that the driver of the Impala did not violate Section 21-309(b) of the Transportation Article, the offense for which Mr. Roach ultimately received a citation, but also urges us to find that Mr. Roach "was lawfully operating his vehicle" and that " 'almost' causing an accident is insufficient to support a traffic stop." Steck relies on Lewis v. State , a case in which the Court of Appeals did not uphold a traffic stop and subsequent vehicle search because the Court determined that Lewis had not violated any law, traffic or other. 398 Md. at 368 , 920 A.2d

2018Steck not only urges this Court to find that the driver of the Impala did not violate Section 21-309(b) of the Transportation Article, the offense for which Mr. Roach ultimately received a citation, but also urges us to find that Mr. Roach "was lawfully operating his vehicle" and that " 'almost' causing an accident is insufficient to support a traffic stop." Steck relies on Lewis v. State , a case in which the Court of Appeals did not uphold a traffic stop and subsequent vehicle search because the Court determined that Lewis had not violated any law, traffic or other. 398 Md. at 368 , 920 A.2d

12018–2018
Burns v. State green
mdctspecapp · 2003
2 sentences

2010We conclude that it was reasonable for the police officers on the scene to stop the processing of the traffic stop and concentrate their efforts on the apprehension of a person known to have an outstanding warrant and that such activity was not an undue extension of the time for the traffic stop. * * * It was reasonable for the officers to conclude that these three persons, traveling together that evening, with histories of drug use and selling, and with a large amount of cash on the person of one and CDS on the person of the other were involved in the common activities of using and selling CD

2010We conclude that it was reasonable for the police officers on the scene to stop the processing of the traffic stop and concentrate their efforts on the apprehension of a person known to have an outstanding warrant and that such activity was not an undue extension of the time for the traffic stop. * * * It was reasonable for the officers to conclude that these three persons, traveling together that evening, with histories of drug use and selling, and with a large amount of cash on the person of one and CDS on the person of the other were involved in the common activities of using and selling CD

12010–2010
Whitehead v. State green
mdctspecapp · 1997
2 sentences

2000We observe from the record that part of his activity was to engage the two occupants of the automobile in conversation about the details of their journey to determine whether they were consistent. 116 Md.App. at 503 , 698 A.2d 1115 (emphasis supplied).

2000We observe from the record that part of his activity was to engage the two occupants of the automobile in conversation about the details of their journey to determine whether they were consistent. 116 Md.App. at 503 , 698 A.2d 1115 (emphasis supplied).

12000–2000

Where else courts name it

OH 33 (2003–2026) TX 33 (1873–2025) MD 23 (1995–2020) IL 23 (1966–2026) AR 22 (2001–2026) CA 21 (1960–2026) PA 19 (1974–2025) LA 16 (2001–2022) GA 14 (1997–2024) FL 13 (1993–2023) IA 11 (2008–2025) WY 11 (2000–2021) AL 10 (1976–2018) OR 9 (1978–2026) MO 9 (1913–2009) WA 7 (1951–2015) TN 7 (1997–2022) DE 7 (2001–2021) MA 6 (1970–2018) MI 5 (1975–2018) CT 5 (1991–2022) NY 5 (1895–2017) SD 5 (1996–2013) KS 4 (1944–2025) VA 4 (2005–2016) AZ 3 (1976–2015) SC 3 (2005–2018) AK 2 (2005–2008) ND 2 (2005–2021) HI 2 (1997–2014) UT 2 (2013–2017) DC 2 (1985–2026) VT 2 (2000–2002) IN 2 (2017–2023) KY 2 (2025–2025) MN 2 (1996–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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