Justia Civil Rights Opinion Summaries

A highway patrol trooper noticed a car driven by Vance Morris did not have a visible license plate. Once he pulled Morris over, the trooper realized the car had a valid temporary registration tag displayed in its rear window. The trooper approached and spoke to Morris, ultimately gathering evidence leading to Morris's conviction for, inter alia, possession of a controlled substance and driving under the influence of alcohol or drugs. The court of appeals reversed, concluding that once the trooper realized his mistake, he lost the reasonable suspicion that justified the traffic stop, and any contact or further detention of Morris was unreasonable. The Supreme Court reversed, holding (1) when an officer acting in good faith is reasonably mistaken about the grounds for a traffic stop, he may initiate contact with the driver to explain his mistake but may not detain the driver any further, and, if during this encounter, new reasonable suspicion of criminal activity arises, the officer may act accordingly; and (2) because the trooper's stop was based on an objectively reasonable mistake of fact, he was allowed to approach Morris, and the odor of alcohol detected during this encounter allowed the trooper to constitutionally detain Morris further.

Chance Robinson was charged with unlawful possession or use of a controlled substance based on the presence of methamphetamine in his bloodstream. The charge was grounded on provisions of the Utah Controlled Substances Act that make it unlawful for any person to "knowingly and intentionally" have "any measurable amount of a controlled substance in [his or her] body." Robinson pleaded guilty to the charges. On appeal Robinson argued that Utah's measurable amount provision violates the Utah and United States Constitutions. The Supreme Court affirmed the decision of the district court, holding (1) the provision does not violate the due process or the uniform operation of laws clause of the Utah Constitution; (2) the provision does not violate the constitutional principles set forth in Robinson v. California because it punishes the act of using or being under the influence of a controlled substance while in utah and requires the State to prove that such use was knowing and intentional; and (3) the provision does not violate the Due Process Clause of the Fourteenth Amendment.