ticket violation in Indiana

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)).

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)).

2023Id. [29] The State argued the officer had reasonable suspicion to detain Wells for approximately forty minutes after the beginning of the traffic stop because Court of Appeals of Indiana | Opinion 22A-CR-2877 | November 2, 2023 Page 14 of 20 “Wells’s extreme nervousness and fidgetiness” was indicative of methamphetamine use.

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

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

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)).

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.