State v. Donaldson

An officer stopped Defendant for a traffic violation. When the officer ordered Defendant out of his vehicle to sign the citation, he observed what appeared to be a bag of cocaine on the floorboard of the driver's side. Charged with possession with intent to sell or deliver twenty-six grams or more of cocaine in a school zone, Defendant moved to suppress the evidence as the product of an unlawful seizure. The trial court sustained the motion, concluding that the request to exit the vehicle was not reasonably related to the stop. The court of criminal appeals affirmed. The Supreme Court reversed the order of suppression and remanded the cause for trial, holding than an officer, after making a lawful stop for a traffic violation, may routinely direct the driver outside of the vehicle. View "State v. Donaldson" on Justia Law