Tuesday, November 5, 2013

Brendlin v. California case brief

Brendlin v. California case brief summary
127 S. Ct. 2400 (2007)

CASE SYNOPSIS
Defendant was charged with various methamphetamine offenses and moved to suppress the evidence obtained in searches of his person and the car in which he was a passenger as fruits of an unconstitutional seizure. The Supreme Court of California held suppression was unwarranted as defendant was a passenger. Certiorari was granted to decide whether a traffic stop subjected a passenger, as well as the driver, to Fourth Amendment seizure.

CASE FACTS
After officers stopped a car to check its registration without reason to believe it was being operated unlawfully, one of them recognized defendant, a passenger in the car. Upon verifying that defendant was a parole violator, the officers formally arrested him and searched him, the driver, and the car, finding, among other things, methamphetamine paraphernalia.

DISCUSSION
  • The State conceded that the police had no adequate justification to pull the car over. 
  • The Court held that the relevant question was to ask whether a reasonable person in defendant's position after the car was stopped would have believed himself free to terminate the encounter between the police and himself. 
  • The Court thought that in such circumstances any reasonable passenger would have understood the police officers to be exercising control to the point that no one in the car was free to depart without police permission.

CONCLUSION
The judgment of the Supreme Court of California was vacated, and the case was remanded for further proceedings not inconsistent with the U.S. Supreme Court's opinion.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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