Brendlin v. California
Brendlin pled guilty to methamphetamine manufacturing after he was arrested during the course of a traffic stop. Brendlin was a passenger in a car involved in a routine stop. The police officer recognized Brendlin and, during the course of the stop, obtained confirmation that Brendlin was violating his parole. The officer then arrested Brendlin and seized some substances used for making methamphetamine from the car. Brendlin's motion to suppress the evidence as the fruit of an illegal seizure was denied by the trial court, and then granted by the appellate court.
The Supreme Court of California reversed, finding that Brendlin was not subjected to a "seizure" during the course of the traffic stop, because the officer gave no indication that Brendlin was is the focus of the officer’s investigation or show of authority, and Brendlin's progress was stopped only momentarily. The court ruled that a passenger involved in a traffic stop is not seized as a constitutional matter unless there are additional circumstances that would indicate to a reasonable person that he was the subject of the peace officer’s investigation or show of authority.
Question Presented:
Whether a passenger in a vehicle subject to a traffic stop is thereby “detained” for purposes of the Fourth Amendment, thus allowing the passenger to contest the legality of the traffic stop.
