State v. Gettling

Summary

The Utah Supreme Court held that police unlawfully detained a vehicle passenger after completing the lawful purpose of a traffic stop and conducting a canine sniff without reasonable suspicion. The court nevertheless upheld the denial of the defendant's motion to suppress under the federal good-faith exception because the officer relied on then-settled precedent permitting a vehicle search incident to the driver's arrest.

Holdings

1. Once officers complete the procedures incident to the driver's arrest and the lawful purpose of the traffic stop has concluded, they must release detained passengers unless they possess reasonable articulable suspicion that a passenger is engaged in criminal activity.
2. The federal good-faith exception to the exclusionary rule applies when officers conduct a vehicle search in reasonable reliance on then-settled judicial precedent authorizing the search, so evidence discovered during the search need not be suppressed.

Questions Presented

1. Whether police may continue detaining a vehicle passenger after the traffic stop has concluded and the driver has been arrested, absent reasonable articulable suspicion that the passenger is involved in criminal activity.
2. Whether evidence discovered during the unlawful detention must be suppressed when the officer conducted the vehicle search in reasonable reliance on then-settled precedent authorizing searches incident to the arrest of a vehicle occupant.
3. Whether furtive movements by a passenger or the presence of a narcotics-detection dog at the scene justified extending the traffic stop.

Disposition

affirmed