State v. Chapman

In State v. Chapman, 921 P.2d 446 (Utah 1995), an officer conducted checks on an individual detained on suspicion of violating a loitering ordinance and thereby discovered that the individual was a gang member known to carry a gun. Id. at 448. The officer obtained permission to search the vehicle in which the gang member was found, and discovered a gun stored in accordance with Utah law. Id. The officer then ran a stolen weapons check to determine whether the gun was stolen. Id. The Court held that the stolen weapons check was not properly related in scope to the circumstances justifying the individual's detention--specifically, suspicion of a loitering ordinance violation. Id. at 453. In Chapman, the Court concluded that the officer only strayed into unconstitutional territory when he ran the stolen weapons check, an action wholly unrelated to a suspected violation of a loitering ordinance and conducted in the absence of an articulable suspicion that the gun in question was stolen. Id. at 454.