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

9 Indiana opinions name it 1 courts 2015–2024 1 in the last five years

The cases below were cited by Indiana 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 (6)

CaseFollowedCited
Rodriguez v. United Statesgreen
scotus · 2015 · cited in 9 Indiana opinions naming this issue, 2015–2024
2 sentences

2024The Court held that “[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 350-351, 135 S. Ct. at 1612 (quoting Illinois v. Caballes, 543 U.S. 405, 407 , 125 S. Ct. 834 (2005)).

2020Austin v. State, 997 N.E.2d 1027, 1034 (Ind. 2013) (internal citations omitted). [23] In Rodriguez, 135 S. Ct. at 1612 , the United States Supreme Court held that “[a] seizure justified by only 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 Illinois v. Caballes, 543 U.S. 405, 407 (2005)).

29
Illinois v. Caballesgreen
scotus · 2005 · cited in 6 Indiana opinions naming this issue, 2015–2024
2 sentences

2024The Court held that “[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 350-351, 135 S. Ct. at 1612 (quoting Illinois v. Caballes, 543 U.S. 405, 407 , 125 S. Ct. 834 (2005)).

2024The Court held that “[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 350-351, 135 S. Ct. at 1612 (quoting Illinois v. Caballes, 543 U.S. 405, 407 , 125 S. Ct. 834 (2005)).

16
Bush v. Stategreen
indctapp · 2010 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020See Rodriguez v. United States, 575 U.S. 348, 350-51 , 135 S. Ct. 1609, 1612 (2015). (“A seizure justified only by a police-observed traffic violation, therefore, becomes unlawful [under the Fourth Amendment] if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation.”) (quotations omitted); see also Wells v. State, 922 N.E.2d 697, 700 (Ind. Ct. App. 2010) (“Although a dog sniff is not a search, an officer must have reasonable suspicion of criminal activity in order to detain an individual beyond what is necessary to complete a traffic

11
Patrick Austin v. State of Indianagreen
ind · 2013 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020Austin v. State, 997 N.E.2d 1027, 1034 (Ind. 2013) (internal citations omitted). [23] In Rodriguez, 135 S. Ct. at 1612 , the United States Supreme Court held that “[a] seizure justified by only 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 Illinois v. Caballes, 543 U.S. 405, 407 (2005)).

11
Wells v. Stategreen
indctapp · 2010 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020See Rodriguez v. United States, 575 U.S. 348, 350-51 , 135 S. Ct. 1609, 1612 (2015). (“A seizure justified only by a police-observed traffic violation, therefore, becomes unlawful [under the Fourth Amendment] if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation.”) (quotations omitted); see also Wells v. State, 922 N.E.2d 697, 700 (Ind. Ct. App. 2010) (“Although a dog sniff is not a search, an officer must have reasonable suspicion of criminal activity in order to detain an individual beyond what is necessary to complete a traffic

11
Doran J. Curry v. State of Indianagreen
indctapp · 2017 · cited in 1 Indiana opinions naming this issue, 2018–2018
1 sentence

2018Rodriguez, 135 S.Ct. at 1612 ; see also Curry v. State, 90 N.E.3d 677, 684 (Ind. Ct. App. 2017) (“The critical question is not whether the sniff occurs before or after the officer issues a ticket, but whether conducting the sniff prolongs or adds time to the stop.”), trans. denied. [14] In addition to determining whether to issue a ticket, an officer’s tasks during a traffic stop include ordinary inquiries such as checking the motorist’s driver’s license, determining whether there are outstanding warrants against the driver, and inspecting the automobile’s registration and proof of insurance.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Florida v. Royer green
scotus · 1983
2 sentences

2024The Court held that because addressing the infraction is the purpose of the stop, “it may ‘last no longer than is necessary to effectuate th[at] purpose.’” Id. at 354, 135 S. Ct. at 1614 (quoting Florida v. Royer, 460 U.S. 491, 500 , 103 S. Ct. 1319 (1983), and citing Caballes, 543 U.S. at 407 , 125 S. Ct. 834 ).

2024The Court held that because addressing the infraction is the purpose of the stop, “it may ‘last no longer than is necessary to effectuate th[at] purpose.’” Id. at 354, 135 S. Ct. at 1614 (quoting Florida v. Royer, 460 U.S. 491, 500 , 103 S. Ct. 1319 (1983), and citing Caballes, 543 U.S. at 407 , 125 S. Ct. 834 ).

12024–2024

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) IA 3 (2017–2021) GA 3 (2015–2020) NC 3 (2018–2022) NJ 3 (2020–2021) UT 2 (2017–2017) SD 2 (2018–2025) MO 2 (2018–2023)

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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