Can Police Officer Request License and Registration After Validating Car's Temporary Registration Sticker ?
In United States v. McSwain, 29 F.3d 558 (10th Cir. 1994), the court held an officer violated the Fourth Amendment when he further questioned a motorist and requested his license and registration after he had already determined the validity of the car's temporary registration sticker.
The court reasoned that the officer no longer had reasonable, articulable suspicion that illegal activity had occurred, and therefore his actions exceeded the limits of a lawful investigation. See id. at 561-62;
See also People v. Redinger, 906 P.2d 81, 86 (Colo. 1995) ("The purpose of the initial investigation having been satisfied, and in the absence of any other basis for detention or questioning of Redinger, [the officer's] conduct in requiring Redinger to produce information without either reasonable suspicion or probable cause was unwarranted.").
Similarly, the Ohio Supreme Court has held that detaining a driver and requesting his license and registration after the officer had determined the validity of the car's temporary tag was "akin to the random detentions struck down by the Supreme Court in Delaware v. Prouse." State v. Chatton, 11 Ohio St. 3d 59, 11 Ohio B. 250, 463 N.E.2d 1237, 1240 (Ohio 1984).