State v. Bonacker
Annotate this CaseDefendant was indicted for driving with a revoked license. The indictment stemmed from a traffic stop that a law enforcement officer initiated after he noticed that Defendant's headlights appeared to be at their high-beam setting. Defendant moved to suppress the evidence and statements obtained during the stop of his vehicle, arguing that the stop should have ended after the officer confirmed Defendant did not fail to dim his headlights. The magistrate court denied the motion and later found Defendant guilty. The circuit court affirmed Defendant's conviction, including the magistrate court's denial of Defendant's suppression motion. The Supreme Court affirmed, holding (1) when the officer requested Defendant's driver's license, the officer had not yet completed his investigation of the failure to dim offense, and therefore, the officer's request was within the scope of the investigation attendant to the traffic stop; and (2) accordingly, there was no violation of Defendant's federal or state constitutional rights against unreasonable searches and seizures.
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