A parking infraction constitutes a violation of California’s Vehicle Code and local laws enacted pursuant to the Vehicle Code, and thus an investigatory stop based on a parking violation falls within the scope of the decision in Whren v. United States (1996) 517 U.S. 806, permitting investigatory stops so long as officers have reasonable suspicion that a law has been violated. The Ninth Circuit rejected the defendant’s argument that a civil parking offense was insufficient to justify an investigatory traffic stop.
Case Summaries