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11 Virginia opinions name it 3 courts 2015–2026 9 in the last five years
The cases below were cited by Virginia 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.
| Case | Followed | Cited |
|---|---|---|
Rodriguez v. United Statesgreen2 sentences2026Specifically, “[a] seizure justified only by a police-observed traffic violation, therefore, becomes unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation.” Id. at 350-51 (citation, brackets and quotation marks omitted). 2026Thus, a seizure based on a traffic stop alone “‘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. at 350-51 (alterations in original) (quoting Illinois v. Caballes, 543 U.S. 405, 407 (2005)). | 8 | 9 |
Illinois v. Caballesgreen2 sentences2026Thus, a seizure based on a traffic stop alone “‘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. at 350-51 (alterations in original) (quoting Illinois v. Caballes, 543 U.S. 405, 407 (2005)). 2025“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. at 350-51 (alterations in original) (quoting Caballes, 543 U.S. at 407 ). | 5 | 9 |
Evans v. Commonwealthgreen1 sentence2025However, “[i]f an officer develops independent reasonable suspicion or probable cause that an occupant has committed an additional traffic offense or crime, the officer may extend the stop for a reasonable amount of time in order to confirm or dispel that new suspicion.” Williams v. Commonwealth, 71 Va. App. 462 , 482 (2020). -4- “When used as a standard of calibrating certitude, ‘[t]he very phrase “probable cause” confirms that the Fourth Amendment does not demand all possible precision.’” Evans v. Commonwealth, 290 Va. 277, 287 (2015) (alteration in original) (quoting Herring v. United State | 1 | 1 |
Herring v. United Statesgreen1 sentence2025However, “[i]f an officer develops independent reasonable suspicion or probable cause that an occupant has committed an additional traffic offense or crime, the officer may extend the stop for a reasonable amount of time in order to confirm or dispel that new suspicion.” Williams v. Commonwealth, 71 Va. App. 462 , 482 (2020). -4- “When used as a standard of calibrating certitude, ‘[t]he very phrase “probable cause” confirms that the Fourth Amendment does not demand all possible precision.’” Evans v. Commonwealth, 290 Va. 277, 287 (2015) (alteration in original) (quoting Herring v. United State | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
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.
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.