State v. Ellenbecker
In State v. Ellenbecker, 159 Wis. 2d 91, 464 N.W.2d 427 (Wis. App. 1990), the court faced the issue of "whether an officer who learns that a motorist needs no assistance may still demand to see a driver's license and conduct a status check at the scene." 464 N.W.2d at 428.
In applying the balancing test required to evaluate a Fourth Amendment claim, the Ellenbecker court determined that legitimate governmental interests were promoted by police officers asking for driver licenses to identify all motorists they contacted for assistance purposes, namely, ensuring accuracy in written reports and protecting against later claims of improper behavior on the part of officers. 464 N.W.2d at 430.
Additionally, Ellenbecker noted that Wisconsin statutes implicitly recognized this governmental interest because a relevant statute required Wisconsin drivers to surrender their licenses on demand.
Furthermore, the governmental interest extended to allowing the officer to run a status check on the license because "statutory authority for police to demand a driver's license would mean little if the police could not check the validity of the license." Id.