Brendlin v. California, 551 U.S. 249 (2007)
Primary Holding
A passenger in a vehicle is seized within the meaning of the Fourth Amendment when a police officer makes a traffic stop, and therefore has the standing to challenge the constitutionality of the stop.
In the case of Brendlin v. California, the Supreme Court decided that when a police officer stops a car, not only the driver but also the passengers are considered "seized" under the law. This is important because it means that passengers have the right to challenge the legality of the traffic stop if they believe it was unconstitutional. This case is relevant if you find yourself as a passenger in a vehicle that is stopped by police, as it protects your rights and gives you a way to contest any unlawful actions taken during that stop.
AI-generated plain-language summary to help you understand this case
On November 27, 2001, Deputy Sheriff Robert Brokenbrough and his partner observed a parked Buick with expired registration tags. After confirming that the vehicle had a temporary operating permit that was valid, the officers decided to pull the car over to verify the permit's details. During the stop, Brokenbrough recognized the passenger, Bruce Brendlin, as a known parole violator with an outstanding no-bail warrant. After calling for backup, Brokenbrough ordered Brendlin out of the car at gunpoint and arrested him. A search incident to his arrest revealed an orange syringe cap on Brendlin, while a search of the driver, Karen Simeroth, uncovered syringes and a plastic bag containing a green leafy substance. The officers also searched the vehicle, finding additional drug-related paraphernalia. Brendlin was subsequently charged with possession and manufacture of methamphetamine and sought to suppress the evidence obtained during the searches, arguing that the traffic stop constituted an unlawful seizure of his person due to a lack of probable cause or reasonable suspicion. The trial court denied his motion to suppress, ruling that he was not seized until he was ordered out of the car and formally arrested. Brendlin pleaded guilty but reserved the right to appeal the suppression issue. The California Court of Appeal initially reversed the trial court's decision, stating that Brendlin was seized during the traffic stop, which they deemed unlawful. However, the Supreme Court of California later reversed this ruling by a narrow majority, asserting that a passenger is not considered seized under these circumstances, despite acknowledging that the officers lacked reasonable suspicion for the stop. The case ultimately reached the U.S. Supreme Court on a writ of certiorari to determine whether a passenger in a vehicle is seized within the meaning of the Fourth Amendment when the vehicle is stopped by law enforcement. The Court's decision addressed the broader implications of passenger rights during traffic stops and the interpretation of what constitutes a seizure under the Fourth Amendment.
Whether a passenger in a vehicle is seized within the meaning of the Fourth Amendment when a police officer makes a traffic stop, and thus has the standing to challenge the constitutionality of the stop.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- April 23, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
Illinois v. Caballes, 543 U.S. 405 (2005)
Consumer LostThe use of a drug-detection dog to sniff a vehicle during a lawful traffic stop does not violate the Fourth Amendment, provided that the stop is not unreasonably prolonged beyond the time necessary to complete the mission of issuing a warning ticket.
Samson v. California, 547 U.S. 843 (2006)
Consumer LostA suspicionless search of a parolee conducted under California law does not violate the Fourth Amendment, as the conditions of parole significantly diminish the parolee's reasonable expectation of privacy.
Hudson v. Michigan, 547 US 586 (2006)
Consumer LostThe violation of the "knock-and-announce" rule does not require the suppression of evidence obtained during a search conducted pursuant to a valid warrant.
Los Angeles County v. Rettele, 550 U.S. 609 (2007)
Consumer LostThe deputies' actions in ordering innocent residents out of bed during the execution of a valid search warrant, without knowledge of their presence or the fact that the suspects had moved out, constituted a violation of the Fourth Amendment's protection against unreasonable searches and seizures.