Utah Supreme Court
Can police extend a traffic stop to investigate drug possession? State v. Binks Explained
Summary
Michael Binks was convicted of drug possession after officers stopped his vehicle as he left an apartment being searched under a drug warrant. The district court denied Binks’s motion to suppress evidence obtained during the stop. The Utah Supreme Court affirmed, holding the Terry stop was reasonable because officers had reasonable suspicion to investigate multiple offenses including traffic violations, DUI, and drug possession.
Practice Areas & Topics
Analysis
Background and Facts
On June 26, 2014, Utah County Major Crimes Task Force officers were executing a search warrant on an American Fork apartment for narcotics and drug paraphernalia. Detective Crawford observed Michael Binks and another person arrive at the apartment, enter for two to three minutes, then leave in a silver SUV. Crawford radioed for officers to stop the vehicle, noting the SUV had failed to signal when exiting. During the stop, officers observed additional traffic violations and signs suggesting Binks was under the influence, including glossy, bloodshot eyes and nervousness.
Key Legal Issues
The central issue was whether officers could continue detaining Binks after completing their investigation of the traffic violations and suspected DUI. Binks argued that once officers finished the sobriety tests and record checks by 8:16 a.m., they should have released him rather than continuing to investigate suspected drug possession until receiving confirmation at 8:22 a.m. that he had purchased methamphetamine.
Court’s Analysis and Holding
The Utah Supreme Court applied the Terry v. Ohio framework, which permits brief detention based on reasonable, articulable suspicion of criminal wrongdoing. The Court held that officers had reasonable suspicion to investigate multiple separate offenses: two traffic violations, driving under the influence, and drug possession. The Court emphasized that Binks’s brief visit to an apartment under a drug warrant, combined with his physical appearance, provided reasonable suspicion of drug possession. Officers were entitled to continue the detention while investigating this additional suspected offense.
Practice Implications
This decision clarifies that Terry stops may extend beyond the initial justification when officers develop reasonable suspicion of additional offenses. Practitioners should carefully analyze the timeline of stops and document all observations supporting reasonable suspicion for each suspected crime. The Court’s decision reinforces that officers need not release a suspect after completing investigation of one offense if reasonable suspicion exists for investigating another. Defense counsel should challenge whether the totality of circumstances truly supported reasonable suspicion for each alleged offense.
Case Details
Case Name
State v. Binks
Citation
2018 UT 11
Court
Utah Supreme Court
Case Number
No. 20160235
Date Decided
March 6, 2018
Outcome
Affirmed
Holding
Officers may continue a Terry stop to investigate drug possession when they have reasonable suspicion of that offense, even after completing investigation of the initial traffic violations that justified the stop.
Standard of Review
The opinion does not explicitly state the standard of review for Fourth Amendment suppression issues
Practice Tip
Document all observations supporting reasonable suspicion of each offense being investigated during a Terry stop, as officers may continue detention to investigate additional suspected crimes beyond the initial justification for the stop.
Need Appellate Counsel?
Lotus Appellate Law handles appeals before the Utah Court of Appeals, Utah Supreme Court, California Court of Appeal, and the United States Court of Appeals for the Tenth Circuit.
Related Court Opinions
About these Decision Summaries
Lotus Appellate Law publishes these summaries to keep practitioners informed — not as legal advice. Each case turns on its own facts. If a decision here is relevant to your matter, we’re happy to discuss it.