Time and Detentions, Part II: Recent Cases to Help Guide You in Traffic Stops

From the Classroom  
By Raymond Hill  
Professor Emeritus, Santa Rosa Junior College 

Time and Detentions Part II – 2023 Cases 

This is the second article in this series. We previously covered Time and Detentions – The Basics. Given that body of refresher, we will now look at three 2023 cases comparing the facts against existing case precedent – two in which the defense won, and one where prosecutors prevailed. 

Where The People Prevailed 

First, from San Diego, we have this ruling: During a traffic stop, taking the time to ensure officer safety does not unduly prolong the detention (Peo. v. Esparza (2023) 4DCA 2023 Cal. App. Lexis 741). 

At the direction of a gang detective, two San Diego police officers pulled over the defendant’s vehicle for illegally tinted windows. The detective knew the area of the stop was contested gang territory. There were four occupants in the vehicle, including the defendant, Esparza, the driver. 

The investigating officer asked for the defendant’s driver’s license, which the defendant initially was unable to produce. Two minutes later, a veteran gang detective arrived on scene and advised that three of the vehicle occupants, including ....

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