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Brendlin v. California

Supreme Court of United States
127 S. Ct. 2400 (2007)
ELI5:

Rule of Law:

During a traffic stop, a passenger in the stopped vehicle is seized within the meaning of the Fourth Amendment. Therefore, a passenger has standing to challenge the constitutionality of the stop.


Facts:

  • Deputy Sheriff Robert Brokenbrough observed a Buick with expired registration tags, but upon checking the dispatcher, learned a renewal application was in process.
  • Later, Brokenbrough saw the same car displaying a valid temporary operating permit for the current month.
  • Despite seeing the valid permit, Brokenbrough initiated a traffic stop to verify that the permit matched the vehicle.
  • The driver was Karen Simeroth, and the passenger was Bruce Brendlin, whom Brokenbrough recognized.
  • Brokenbrough recalled that one of the Brendlin brothers was a parole absconder and asked Bruce Brendlin for identification.
  • The officer returned to his vehicle and confirmed that Brendlin was a parole violator with an outstanding no-bail arrest warrant.
  • While the officer was verifying this information, Brendlin briefly opened and then closed the passenger door.
  • Upon the arrival of backup, officers ordered Brendlin out of the car at gunpoint, arrested him, and conducted a search, finding drug paraphernalia on him, Simeroth, and in the car.

Procedural Posture:

  • Brendlin was charged with possession and manufacture of methamphetamine in California state trial court.
  • Brendlin filed a motion to suppress evidence found during the stop, arguing it was the fruit of an unconstitutional seizure.
  • The trial court denied the suppression motion, finding that Brendlin was not seized until his formal arrest.
  • Brendlin pleaded guilty but preserved his right to appeal the denial of his suppression motion.
  • The California Court of Appeal (an intermediate appellate court) reversed the trial court, holding that Brendlin was seized during the initial traffic stop, which it found to be unlawful.
  • The Supreme Court of California (the state's highest court), as appellee, reversed the Court of Appeal, holding that a passenger is not seized during a traffic stop absent additional circumstances indicating the passenger is the target of the stop.
  • The U.S. Supreme Court granted certiorari to resolve the issue.

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Issue:

Does a police officer's traffic stop of a vehicle effect a seizure of a passenger inside, within the meaning of the Fourth Amendment, thereby allowing the passenger to challenge the stop's constitutionality?


Opinions:

Majority - Justice Souter

Yes. A traffic stop of a vehicle effects a seizure of a passenger inside, within the meaning of the Fourth Amendment. A person is considered seized when a reasonable person in their position would not feel free to terminate the encounter with the police. In the context of a traffic stop, the display of authority by police in stopping a vehicle communicates to any reasonable passenger that they are not free to depart without the officer's permission. The stop curtails the passenger's freedom of movement just as it does the driver's. The court rejected California's argument that the officer's subjective intent to stop only the driver was controlling, reaffirming that the objective test of what a reasonable person would perceive is what governs a Fourth Amendment seizure analysis. Furthermore, a passenger submits to this show of authority by staying in the vehicle after it has been stopped.



Analysis:

This decision unanimously resolved a split among federal and state courts regarding passenger standing to challenge traffic stops. It establishes a clear, bright-line rule that all occupants of a vehicle are seized for Fourth Amendment purposes when police pull the vehicle over. The ruling prevents a significant law enforcement loophole where officers could conduct pretextual or baseless traffic stops to investigate passengers, knowing that any resulting evidence would be admissible if passengers were deemed not to be seized. By affirming that passengers can challenge the legality of the initial stop, the Court reinforced the Fourth Amendment's protection against arbitrary police action for all individuals in a vehicle, not just the driver.

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