police-observed traffic violation (Texas) · Go Syfert
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police-observed traffic violation in Texas

11 Texas opinions name it 2 courts 2015–2024 4 in the last five years

The cases below were cited by Texas 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 (3)

CaseFollowedCited
Rodriguez v. United Statesgreen
scotus · 2015 · cited in 8 Texas opinions naming this issue, 2016–2024
2 sentences

2022Thus, Appellant argues, Officer Wooden prolonged the stop beyond the time reasonably required to complete the mission of issuing a ticket or a warning for the traffic violation when he returned to Appellant’s vehicle to “see what [he could] figure out.” See Rodriguez, 575 U.S. at 350 (“A seizure justified only by a police-observed traffic violation . . . ‘become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission’ of issuing a ticket for the violation.” (quoting Caballes, 543 U.S. at 407 ) (alterations in original)).

2021The Supreme Court of the United States has “held that a seizure justified only by a police-observed traffic violation becomes unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation.” Id. at 193 & n.70 (citing Rodriguez, 575 U.S. at 350–51).

58
Davis v. Stategreen
texcrimapp · 1997 · cited in 2 Texas opinions naming this issue, 2016–2021
2 sentences

2021See Evans, 500 S.W.3d at 537; see also Rodriguez, 575 U.S. at 354 (“A seizure justified only by a police-observed traffic violation . . . become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission of issuing a ticket for the violation.”); Davis v. State, 947 S.W.2d 240, 243 (Tex. Crim.

2016Cf. Rodriguez v. United States, 575 U.S. ___ , ___, 135 S. Ct. 1609, 1611 (2015) (noting that “[a] seizure justified only by a police-observed traffic violation . . . become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission of issuing a ticket for the violation”); see Davis, 947 S.W.2d at 245 .

22
Lerma v. Stategreen
texcrimapp · 2018 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019Rodriguez, 135 S. Ct. at 1612 ; Lerma, 543 S.W.3d at 193 (“traffic stops may last no longer than necessary to effectuate the purpose of the stop”).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Illinois v. Caballes green
scotus · 2005
2 sentences

2022Thus, Appellant argues, Officer Wooden prolonged the stop beyond the time reasonably required to complete the mission of issuing a ticket or a warning for the traffic violation when he returned to Appellant’s vehicle to “see what [he could] figure out.” See Rodriguez, 575 U.S. at 350 (“A seizure justified only by a police-observed traffic violation . . . ‘become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission’ of issuing a ticket for the violation.” (quoting Caballes, 543 U.S. at 407 ) (alterations in original)).

2016Id. at 1611 , quoting Caballes, 543 U.S. at 407 .

52015–2022

Where else courts name it

OH 25 (2016–2026) TX 11 (2015–2024) VA 10 (2015–2026) IL 10 (2015–2024) IN 9 (2015–2024) MI 6 (2016–2026) ID 6 (2018–2022) PA 5 (2018–2025) CA 4 (2016–2026) ME 4 (2017–2026) KY 4 (2020–2026) GA 3 (2015–2020) NJ 3 (2020–2021) IA 3 (2017–2021) NC 3 (2018–2022) MO 2 (2018–2023) UT 2 (2017–2017) SD 2 (2018–2025)

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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