## Facts

- In two separate, routine traffic stops, police officers asked vehicle passengers for identification without any particularized suspicion that the passengers were engaged in criminal activity.
- In Rankin’s stop (Snohomish County), a deputy stopped a vehicle for a noncriminal traffic infraction; Rankin was the passenger.
- The deputy did not observe Rankin commit any crime during the stop but asked Rankin for identification; Rankin provided an identification card.
- The deputy ran a warrants check using the identification information, discovered an outstanding warrant, arrested Rankin, and found methamphetamine (and a knife) during a search incident to arrest.
- In Staab’s stop (King County), an officer requested Staab’s identification during a lawful traffic infraction stop, ran a warrants check, discovered an outstanding warrant, arrested Staab, and found contraband during a search incident to arrest.
- Trial court outcomes diverged: Rankin’s evidence was suppressed and the case dismissed; Staab’s suppression motion was denied and he was convicted.
- The intermediate appellate court held officers may request (but not demand) passenger identification and ruled against both defendants; the Washington Supreme Court granted review in the consolidated cases.

## Issues

1. Whether article I, section 7 of the Washington Constitution is violated when, during a lawful traffic stop, an officer requests identification from a passenger for investigative purposes without an independent, articulable suspicion that the passenger has engaged in criminal activity.
2. Whether evidence obtained after discovering an outstanding warrant through such a request must be suppressed as the product of the constitutional violation.

## Decision

- The Washington Supreme Court reversed the intermediate appellate court in both cases.
- The court held that requesting passenger identification for investigative purposes during a traffic stop, absent independent articulable suspicion of passenger criminal activity, violates article I, section 7.
- Rankin: the trial court’s suppression ruling (and resulting dismissal) was reinstated.
- Staab: the conviction was reversed and the matter remanded for proceedings consistent with suppression of evidence obtained after the unlawful identification request.

## Legal Principles

- Article I, section 7 (“No person shall be disturbed in his private affairs ... without authority of law”) protects automobile passengers’ privacy during traffic stops.
- In the traffic-stop setting, an officer’s “request” for passenger identification for investigative purposes is treated as a constitutionally significant intrusion because the encounter is inherently coercive.
- Police may not convert a driver-based traffic stop into an investigatory warrant-check of a passenger by seeking identifying information unless there is an independent, articulable suspicion tied to the passenger.
- Evidence discovered through arrest and search incident to arrest following a warrant found only because of the unlawful identification request is subject to suppression as fruit of the violation.

## Conclusion

The Washington Supreme Court held that article I, section 7 prohibits officers from requesting passenger identification for investigative warrant checks during a lawful traffic stop unless the officer has an independent, articulable suspicion that the passenger is involved in criminal activity, requiring suppression of evidence derived from the unlawful request.


State v. Rankin, 151 Wn. 2d 689, 92 P.3d 202 (Wash. 2004)