People v. Cartwright

Opinion

BEDSWORTH, J.

Analysis of contacts between police officers and passengers in motor vehicles has nettled California courts for some time. Some have held that passengers are not detained for Fourth Amendment purposes simply because they are present inside a car stopped for a traffic violation; others have reached the opposite conclusion. Even where courts have agreed on a result, they have differed over the reasoning that applies.

In this case, we try our hand at it with the guidance of United States Supreme Court precedent and conclude the typical traffic stop does not, by itself,…