State v. Martinez: requesting that a passenger provide identification following traffic stop, and then running a background check on that passenger without reasonable suspicion that the passenger had committed, or was about to commit, a crime did not violate the Fourth Amendment

An officer may request that a passenger provide identification because the officer safety concerns justified the negligibly burdensome extension of the traffic stop.See State v. Martinez, 2017 UT 43, 424 P.3d 83.

A Utah Highway Patrol Trooper stopped a vehicle for an improper lane change and asked both the driver and George Matthew Martinez, a passenger, for identification. The trooper ran a warrant check and learned that Martinez had an outstanding arrest warrant. The officer searched Martinez incident to his arrest and discovered a glass pipe with methamphetamine residue inside. The issue in this case was whether a law enforcement officer violate the Fourth Amendment if she requests that a passenger voluntarily provide identification and then runs a background check on that passenger without reasonable suspicion that the passenger has committed—or is about to commit—a crime. Martinez sought to exclude the evidence, arguing that the officer had violated his Fourth Amendment rights. Martinez claimed that “‘[a]ny further temporary detention’ for investigative questioning after fulfilling the original purpose for the traffic stop constitutes an illegal seizure, unless an officer has probable cause to arrest or a reasonable suspicion of a further illegality.” However, the court recognized that “certain measures promoting officer safety fall within the permissible scope of a traffic stop,” and concluded that the Trooper’s voluntary interaction with Martinez did not violate Martinez's Fourth Amendment rights and the negligible extension of the stop by running Martinez’s background did not unreasonably prolong the detention.