What is the current state of the law in relation to the seizure of a person in a traffic stop?

Police who observe a traffic violation may stop and detain a defendant to investigate that violation. (Rodriguez, supra, 191 L.Ed.2d at pp. 496, 498.) However, such a seizure may "become unlawful if it is prolonged beyond the time reasonably required to complete that mission." (Illinois v. Caballes (2005) 543 U.S. 405, 407 [160 L.Ed.2d 842, 846] (Caballes).) "[T]he tolerable duration of police inquiries in the traffic-stop context is determined by the seizure's 'mission' -- to address the traffic violation that warranted the stop, [citation] and attend to related safety concerns, [citation]. [Citations.] Because addressing the infraction is the purpose of the stop, it may 'last no longer than is necessary to effectuate th[at] purpose.' [Citations.] Authority for the seizure thus ends when tasks tied to the traffic infraction are -- or reasonably should have been -- completed." (Rodriguez, at p. 498.) Such tasks include those related to ensuring vehicles on the road are operated safely and responsibly, including validating

Page 7

a license and registration, searching for outstanding warrants, and checking for proof of insurance. (Id. at p. 499.)