Brendlin V. California - Facts

Facts

In the early morning hours of November 27, 2001, a deputy sheriff and his partner effected a traffic stop on the car in which Bruce Brendlin was riding. The car's registration had expired, but the owner had applied for a renewal, and a valid temporary registration permit was properly affixed to the car. Nevertheless, the deputy decided to investigate further. He asked the driver of the car, Karen Simeroth, for her license, and noticed that Bruce Brendlin, "one of the Brendlin brothers," was sitting in the passenger seat. The deputy determined that there was a warrant out for Brendlin's arrest, and so he called for backup. Once backup arrived, Brendlin and Simeroth were arrested. The police found an orange syringe cap on Brendlin's person, more syringes and a "green leafy substance" on Simeroth's person, and equipment used to manufacture methamphetamine in the car.

Brendlin was charged with possession and manufacture of methamphetamine. Before trial, he moved to suppress the evidence found on his person and in the car as fruits of an unlawful seizure—unlawful because, he argued, the police had neither probable cause nor reasonable suspicion to make the traffic stop. The trial court denied the motion, reasoning that Brendlin was first "seized" at the point he was removed from the car and arrested. Brendlin pleaded guilty but reserved the right to appeal the suppression issue, and was sentenced to four years in prison.

The California Court of Appeal reversed the trial court's denial of the motion to suppress. However, the California Supreme Court reversed the Court of Appeal, reinstating the trial court's decision. Although the State conceded that the police had no lawful basis to effect the traffic stop, the California Supreme Court still held that the trial court was correct in denying the motion to suppress because, it reasoned, "a passenger is not seized as a constitutional matter in the absence of additional circumstances that would indicate to a reasonable person that he or she was the subject of the peace officer's investigation or show of authority." Simeroth was the exclusive target of the traffic stop, and so Brendlin was not seized until the police did something else to cast their eyes upon him. The decision was at odds with several federal circuit courts of appeal. Upon appeal, the U.S. Supreme Court held that the passenger was "seized" as soon as the vehicle was pulled over, vacated the decision of the California Supreme Court, and remanded the case to allow the California courts to determine whether suppression turned on any other issue.

The issue before the Court was whether a passenger in a vehicle subject to a traffic stop is thereby "detained" for purposes of the Fourth Amendment, thus allowing the passenger to contest the legality of the traffic stop.

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Facts

Facts usually refers to the usage as a plural noun of fact, an incontrovertible truth. Facts may also refer to:

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  • Fact - Fact in Data Warehousing
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  • Facts (convention) - a comic, scifi and anime festival in Belgium
Soccer AM - Footballing Features - Itso Facto
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