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

10 Illinois opinions name it 1 courts 2015–2024 2 in the last five years

The cases below were cited by Illinois 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 (5)

CaseFollowedCited
Illinois v. Caballesgreen
scotus · 2005 · cited in 9 Illinois opinions naming this issue, 2015–2024
2 sentences

2024“A seizure justified only by a police-observed traffic violation, therefore, ‘become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission’ of issuing a ticket for the violation.” Id. (quoting Caballes, 543 U.S. at 407 ).

2020All told, “[a] reasonable suspicion is considerably less than proof of wrongdoing by a preponderance of the evidence and ‘obviously less’ than that necessary for probable cause.” Dunmire, 2019 IL App (4th) 190316, ¶ 41 (quoting Navarette v. California, 572 U.S. ___ , ___, 134 S. Ct. 1683, 1687 (2014)). -6- ¶ 16 Be it based on either probable cause or reasonable suspicion, “[a] seizure justified only by a police-observed traffic violation” may “ ‘become[ ] unlawful if it is prolonged beyond the time reasonably required to complete [the] mission’ of issuing a ticket for the violation.” Rodriguez

49
Rodriguez v. United Statesgreen
scotus · 2015 · cited in 10 Illinois opinions naming this issue, 2015–2024
2 sentences

2024“A seizure justified only by a police-observed traffic violation, therefore, ‘become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission’ of issuing a ticket for the violation.” Id. (quoting Caballes, 543 U.S. at 407 ).

2021All told, “[a] reasonable suspicion is considerably less than proof of wrongdoing by a preponderance of the evidence and ‘obviously less’ than that necessary for probable cause.” Dunmire, 2019 IL App (4th) 190316, ¶ 41 (quoting Navarette v. California, 572 U.S. ___ , ___, 134 S. Ct. 1683, 1687 (2014)). ¶ 16 Be it based on either probable cause or reasonable suspicion, “[a] seizure justified only by a police-observed traffic violation” may “ ‘become[ ] unlawful if it is prolonged beyond the time reasonably required to complete [the] mission’ of issuing a ticket for the violation.” Rodriguez v.

210
People v. Dunmiregreen
illappct · 2021 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021All told, “[a] reasonable suspicion is considerably less than proof of wrongdoing by a preponderance of the evidence and ‘obviously less’ than that necessary for probable cause.” Dunmire, 2019 IL App (4th) 190316, ¶ 41 (quoting Navarette v. California, 572 U.S. ___ , ___, 134 S. Ct. 1683, 1687 (2014)). ¶ 16 Be it based on either probable cause or reasonable suspicion, “[a] seizure justified only by a police-observed traffic violation” may “ ‘become[ ] unlawful if it is prolonged beyond the time reasonably required to complete [the] mission’ of issuing a ticket for the violation.” Rodriguez v.

2020All told, “[a] reasonable suspicion is considerably less than proof of wrongdoing by a preponderance of the evidence and ‘obviously less’ than that necessary for probable cause.” Dunmire, 2019 IL App (4th) 190316, ¶ 41 (quoting Navarette v. California, 572 U.S. ___ , ___, 134 S. Ct. 1683, 1687 (2014)). -6- ¶ 16 Be it based on either probable cause or reasonable suspicion, “[a] seizure justified only by a police-observed traffic violation” may “ ‘become[ ] unlawful if it is prolonged beyond the time reasonably required to complete [the] mission’ of issuing a ticket for the violation.” Rodriguez

22
Prado Navarette v. Californiagreen
scotus · 2014 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021All told, “[a] reasonable suspicion is considerably less than proof of wrongdoing by a preponderance of the evidence and ‘obviously less’ than that necessary for probable cause.” Dunmire, 2019 IL App (4th) 190316, ¶ 41 (quoting Navarette v. California, 572 U.S. ___ , ___, 134 S. Ct. 1683, 1687 (2014)). ¶ 16 Be it based on either probable cause or reasonable suspicion, “[a] seizure justified only by a police-observed traffic violation” may “ ‘become[ ] unlawful if it is prolonged beyond the time reasonably required to complete [the] mission’ of issuing a ticket for the violation.” Rodriguez v.

2020All told, “[a] reasonable suspicion is considerably less than proof of wrongdoing by a preponderance of the evidence and ‘obviously less’ than that necessary for probable cause.” Dunmire, 2019 IL App (4th) 190316, ¶ 41 (quoting Navarette v. California, 572 U.S. ___ , ___, 134 S. Ct. 1683, 1687 (2014)). -6- ¶ 16 Be it based on either probable cause or reasonable suspicion, “[a] seizure justified only by a police-observed traffic violation” may “ ‘become[ ] unlawful if it is prolonged beyond the time reasonably required to complete [the] mission’ of issuing a ticket for the violation.” Rodriguez

22
People v. Westgreen
illappct · 2017 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See also West, 2017 IL App (3d) 130802 (McDade, J., dissenting). ¶ 63 After analogizing a routine traffic stop to a Terry stop and citing a number of the Court’s prior decisions, Rodriguez directed that “the tolerable duration of police inquiries *** is determined by the seizure’s ‘mission’—to address the traffic violation that warranted the stop, Caballes, 543 U.S. at 407 , and attend to related safety concerns.” Id. at 354.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
People v. Paddy neutral
illappct · 2017
1 sentence

2017Put another way, a seizure justified by a police-observed traffic violation becomes unlawful if it is prolonged beyond the time reasonably required to complete -7- 2017 IL App (2d) 160395 the mission of issuing a ticket for the violation.

12017–2017

Statutes the citing opinions construe

IL § 720 ILCS 570/401 (5) IL § 725 ILCS 5/114-12 (4) IL § 625 ILCS 5/11-709 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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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