State v. Sargent
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The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.
During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop.
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