California v. Brendlin
Citation and Court
551 U.S. 249 (2007) — Supreme Court of the United States
Facts
Officers stopped a car in which Brendlin was a passenger to check the registration. The stop lacked reasonable suspicion; it was later determined the vehicle registration had actually been properly renewed. During the stop, officers recognized Brendlin as a parole violator, arrested him, and found methamphetamine paraphernalia on his person and in the car. Brendlin sought to suppress the evidence, arguing that as a passenger he had been seized when the car was stopped.
Issue
Is a passenger in a vehicle seized within the meaning of the Fourth Amendment when police conduct a traffic stop of the vehicle?
Holding
Yes; when police stop a vehicle, all occupants of the vehicle—including passengers—are seized for Fourth Amendment purposes.
Rule / Doctrine
A traffic stop is a seizure of the driver and all passengers. The test is whether a reasonable person in the passenger’s position would feel free to decline the officers’ requests or otherwise terminate the encounter. Because passengers cannot simply get up and leave, they are seized throughout the stop and have standing to challenge the constitutionality of the stop.
Significance
Brendlin resolves a circuit split by holding that passengers, not just drivers, are seized during a traffic stop and thus have Fourth Amendment standing to challenge its legality. This dramatically expands who may move to suppress evidence obtained during a traffic stop, and is a significant companion to Whren v. United States and Arizona v. Johnson.