What is the test for detention of a man who was stopped by a police officer at a traffic light violation?

California, United States of America


The following excerpt is from People v. Lamzon, C078871 (Cal. App. 2016):

Defendant's detention was proper because he violated the law (specifically, Vehicle Code section 21201, subdivision (d)(1), which prohibits riding a bicycle at night without a light) and his detention was not unduly prolonged. During a valid traffic stop, an officer may check for identification and outstanding warrants. (Rodriguez v. United States (2015) 575 U.S. ___ [191 L.Ed.2d 492, 499].) Police may make unrelated inquiries " 'so long as [unrelated] inquiries do not measurably extend the duration of the stop.' " (Ibid.) If a suspect cannot produce identification for examination, an officer has discretion to take additional steps to ensure the accuracy of any identification the suspect provided. (People v. McKay (2002) 27 Cal.4th 601, 621.)

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