Court Ruling Upholds Traffic Stop Prolongation, Seizure of Vehicle, and Enforcement of Federal Law

Mission of a Traffic Stop: 

Lawful Prolongation of a Traffic Stop Based Upon Newly Developed Reasonable Suspicion: 

Enforcement of Federal Law by a State Law Enforcement Officer 

Probable Cause to Seize a Vehicle 

Probable Cause to Search a Vehicle

United States v. Steinman (9th Cir. Mar. 5, 2025) __ F.4th __ [2025 U.S.App. LEXIS 5127] 

Rule: A traffic stop must be completed during the time it reasonably takes to complete the mission of the traffic stop.  The mission of a traffic stop may be extended when a reasonable suspicion of other criminal activity is discovered.  A vehicle may be lawfully seized whenever there exists probable cause to believe it contains contraband. A search warrant is not needed to conduct a probable cause search of a vehicle. 

Facts:  On August 12, 2022, Nevada State Trooper William Boyer observed a BMW driving at 89 mph (“well above the posted speed limit”) near Wells, Nevada.  In a contact recorded by the trooper’s bodycam and his vehicle’s dashcam, the Trooper Boyer made a traffic stop at 3:51 p.m.  Defendant Triston Harris Steinman was soon identified as the vehicle’s driver and only occupant.  As Trooper Boyer walked up to the passenger-side window, he observed “movement within the vehicle’s cab.” He could also see in plain sight an ammunition box on the front right floor.  On the back seat was a blanket covering unknown items.  Upon obtaining defendant’s license and registration, defendant told the trooper that he was moving from Washington to Utah and just passing through Nevada.  While talking about this, Trooper Boyer inquired about what was under the blanket in the back seat, to which defendant responded, “stuff;” declining to elaborate.  Defendant eventually admitted to having ammunition in the ammo box, but denied having any guns.  

Trooper Boyer returned to his patrol car to run a driver’s license check to verify the validity of defendant’s license and check whether he had any outstanding warrants or protection orders.  Finding none, the trooper returned to defendant and his vehicle and ....