State v. Mendez

Summary

The Washington Supreme Court held that a passenger in a vehicle stopped for a noncriminal traffic infraction is not automatically subject to police orders to remain in or exit the vehicle under the state constitution. Such an order requires an objective rationale specifically tied to safety or control of the traffic-stop scene, although an investigatory purpose still requires reasonable suspicion. Because the officers lacked such a rationale before ordering Mendez to return to the vehicle, his ensuing detention, arrest, and search were unconstitutional, requiring suppression of the evidence and reversal. There were no separate opinions.