This page uses extracted PDF text. Text can misread numbers, dates or table columns. Check the PDF before quoting or interpreting it. Redacted areas remain redacted.
8
to ensure that Knight-Walker did not continue to break the law by driving away moments after
receiving her summons, not simply to issue a summons.
Practically speaking, the circumstances at hand meant more extended contact between the
officer and two persons, Knight-Walker and the passenger. When “there is more than one
occupant of the vehicle,” it “increases the possible sources of harm to the officer.” Wilson, 519
U.S. at 413. It was also not clear how long it might take for Knight-Walker’s son to arrive. This
more extended period of contact reasonably prompted questions from the officer to ensure that
there were no additional considerations that could heighten the danger while he completed his
enforcement action.
The officer’s actions and questions were reasonable under the particular circumstances he
faced. The “ultimate touchstone of the Fourth Amendment is ‘reasonableness.’” Riley v.
California, 573 U.S. 373, 381-82 (2014) (citation omitted). “An action is ‘reasonable’ under the
Fourth Amendment, regardless of the individual officer’s state of mind, ‘as long as the
circumstances, viewed objectively, justify [the] action.’” Brigham City v. Stuart, 547 U.S. 398,
404 (2006) (emphasis in original) (citation omitted). “The calculus of reasonableness must
embody allowance for the fact that police officers are often forced to make split-second
judgments — in circumstances that are tense, uncertain, and rapidly evolving.” Graham v.
Connor, 490 U.S. 386, 396-97 (1989). Given the misleading confidence of hindsight, the United
States Supreme Court has counseled that “judges should be cautious about second-guessing a
police officer’s assessment, made on the scene, of the danger presented by a particular situation.”
Ryburn v. Huff, 565 U.S. 469, 477 (2012) (per curiam).
Mindful of that admonition, we recognize that law enforcement officers confront a wide
range of situations on a daily basis. Consequently, reviewing courts must give officers some Jump to an indexed page (10 of 10)