Background
Anthony Baker was stopped by police in Watertown, South Dakota, because snow obstructed his license plate. During the stop, Baker could not provide a driver’s license or proof of insurance, appeared nervous, and was found to have marijuana and a firearm in his vehicle. He had a revoked license and an outstanding felony warrant.
The court’s reasoning
The court applied a mixed standard of review, examining factual findings for clear error and legal conclusions de novo. The court found the stop lawful because snow obstructing a license plate violated South Dakota law. The court further held that the stop did not become unconstitutional when the officer extended it to check for warrants and inspect documents, as the driver’s inability to provide identification and evasive behavior created reasonable suspicion of criminal activity.
The district court properly concluded that the officer had a reasonable basis for the stop.
What it means going forward
The decision reinforces that minor traffic violations, including obscured plates, justify stops and that officers may extend stops to investigate suspicious behavior unrelated to the initial violation.