Following is the case brief for Brendlin v. California, Supreme Court of the United States, (2007)
Case summary for Brendlin v. California:
- Brendlin was a passenger in a vehicle stopped by police. Drugs were found inside of the car.
- Brendlin was arrested and charged with possession of drugs and paraphernalia, to which he filed a motion to suppress.
- The trial court denied the motion and Brendlin plead out.
- The Court held that the motion to suppress should have been granted because under the Fourth amendment Brendlin was seized during the traffic stop to which there was no legal basis to initially perform.
Brendlin v. California Case Brief
Statement of the facts:
Police pulled over a driver to allegedly check the vehicle’s permit. One of the policemen recognized the driver’s passenger, Bruce Brendlin and thought he may be out violating his parole. After verification of Brendlin’s outstanding warrant, one of the officers arrested Brendlin confiscating drugs and drug paraphernalia found on Brendlin, the driver and inside of the vehicle. At trial, Brendlin filed a motion to suppress the evidence, claiming the traffic stop was an unlawful seizure.
The trial court denied the motion and Brendlin plead guilty. On appeal, the state supreme court affirmed the trial court’s judgment and the Supreme Court of the United States granted certiorari.
Rule of Law or Legal Principle Applied:
During a traffic stop, the vehicle’s passenger is also seized for Fourth Amendment purposes.
Issue and Holding:
During a traffic stop, is the passenger of a vehicle seized under the Fourth Amendment? Yes.
The Court reversed the state supreme court’s judgment.
The Court held that the trial court should have granted Brendlin’s motion to suppress. Under the Fourth Amendment, a vehicle’s passenger is seized during a traffic stop and may challenge its validity. The Court held that under the Fourth Amendment a seizure is an intentional detention by an officer regardless of whether it is by physical restraint or show of authority, which influences the person’s freedom to move. A seizure occurs when the party submits to an officer.
The Court looked to precedent set out in United States v. Mendenhall, 466 U.S. 544 (1980), which outlines the proper test to determine whether a seizure has occurred. One must examine whether in light of the surrounding circumstances a reasonable person would have believed that they were free to either leave or terminate the encounter.
The Court laid out that a traffic stop by its very nature is a seizure of not only the vehicle, but all occupants as well.
When applying the above standard, the Court concluded that a reasonable passenger in Brendlin’s position would conclude that the vehicle was under police control and was not free to leave.
The test set out in Mendenhall makes it very clear that the test to determine whether a seizure has occurred is not based on an officer‘s subjective intent, but the objective belief and understanding of the passenger, Brendlin. The facts indicate that Brendlin submitted to the seizure when he remained inside of the vehicle.
The Court also pointed out that the passengers in other vehicles would understand that the officers’ show of authority is directed at the stopped vehicle, so it should follow that passengers of the seized vehicle are also seized at that time and can subsequently challenge the stop constitutionality.
This landmark case established that the occupants of a vehicle during a traffic stop are seized under the Fourth Amendment.