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Name: People v. Steele
Case #: C077040
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/25/2016

Officer safety justified the detention of defendant in his vehicle to assure that he did not present a danger to officers while they approached and investigated a vehicle in front of defendant’s vehicle. Officers observed two cars driving down a rural dead end road with no streetlights. They ran a records check on both vehicles and discovered that the lead vehicle’s registered owner had a warrant out for his arrest. When the vehicles stopped at the end of the driveway, the officers activated their emergency lights. They approached the second car first out of concern that its occupant could ambush them if they proceeded straight to the lead car. When they made contact with the driver of the second car, Steele, they smelled marijuana. They searched his car and found drugs. Steele moved to suppress the drug evidence on the basis that his detention was unreasonable. The court denied the motion. Steele pleaded no contest and appealed. Held: Affirmed. Whether a detention is reasonable for Fourth Amendment purposes turns on a balancing of the intrusiveness of the detention against the government interests justifying it. Here, after analyzing Maryland v. Wilson (1997) 519 U.S. 408 and People v. Glaser (1995) 11 Cal.4th 354, the Court of Appeal concluded that, under the totality of the circumstances, Steele’s initial detention was justified for the limited purpose of protecting the officers’ safety. The officers’ initial encounter with Steele was a minimal intrusion on his privacy and security interests. He was already stopped when they activated their emergency lights, the detention was brief, and he was not detained for an independent investigatory purpose. Furthermore, officer safety is a weighty government interest and the concern for officer safety was great here. It was nighttime and the officers were on a rural, unlit, dead end road. The officers did not know the identities of the drivers and there was a risk that Steele could ambush the officers while they contacted the lead car.

The full opinion is available on the court’s website here: