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Knight-Walker v. Commonwealth — 2025 opinion, later reversed

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- 9 - that she could not continue driving because her license was suspended.6 The record does not reflect any indication from either Allen or the second officer that Knight-Walker’s behavior during the stop gave rise to the additional reasonable suspicion necessary to justify prolonging the stop to search the vehicle for drugs, nor does the Commonwealth argue such justification. Therefore, given the specific facts of this particular case, we hold that Allen impermissibly exceeded the bounds of the traffic mission for which he stopped Knight-Walker when he then initiated an unrelated additional investigation without the needed reasonable articulable suspicion to justify additional detention and search of Knight-Walker’s vehicle and subsequently delayed the completion of the next “task” tied to the traffic stop, namely allowing Knight-Walker to “get somebody here and drive the car away” as articulated by the trial court. Relevant to this appeal, the following timeline of events occurred: • Early in the traffic stop, as Knight-Walker and her passenger were looking through her bag, her pockets, and the vehicle for her driver’s license, Allen asked Knight-Walker if there were any weapons in the car, to which Knight-Walker said “No;” • Allen later informed Knight-Walker that her driver’s license was suspended and that she could not drive the car, asking if the passenger could drive the car away from the scene; • When the passenger said he could not drive either, Knight- Walker then stated that she could call her son, and Allen responded “Okay, yeah, just call somebody to come pick you up;” • Allen assured Knight-Walker that he was not going to arrest her but reiterated that she could not drive the car, prompting Knight-Walker to again say “Okay, I’ll call my son;” • Knight-Walker picked up her cell phone to make the call, but before she could even attempt to make a call, Allen interrupted by saying “Okay, I know I asked you [inaudible]—I’ll make 6 It is also worth noting that because Knight-Walker pulled into a CVS parking lot and the vehicle was subsequently parked there for the duration for the stop, it was not a danger to other motorists. Therefore, the vehicle did not need to be towed and Allen’s search could not be justified as an inventory search pursuant to having the vehicle towed away from the stop.
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