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imputed under the collective knowledge doctrine feet before turning. Nor does Zuniga dispute that
to Officer Pruit, who effected the stop and Detective Chavarria radioed information about the
conducted the search. turn-signal violation to his colleagues as soon as
he saw it occur, although none of the other officers
The Fourth Amendment protects individuals were in position to stop the vehicle at the time.
against unreasonable searches and seizures. Thus, in following the Copeland courts lead in
U.S. Const. amend. IV. Traffic stops are deemed considering the circumstances surrounding the
seizures for the purposes of the Fourth stop, we hold that the totality of the
Amendment. For a traffic stop to be justified at circumstances do not dictate a finding that the
its inception, an officer must have an objectively turn-signal violation was too stale to justify
reasonable suspicion that some sort of illegal stopping the vehicle. That is to say, the delay here
activity, such as a traffic violation, occurred, or is is not enough to negate the violation as grounds
about to occur, before stopping the vehicle. The for the later stop.
Supreme Court has stated that in making a
reasonable suspicion inquiry, a court must look at We make no attempt to articulate a specific time
the totality of the circumstances of each case to limitation to which officers must adhere in
see whether the detaining officer has a effecting a stop following a traffic violation.
particularized and objective basis for suspecting Rather, we stress that, consistent with our holdings
legal wrongdoing. We have further instructed in similar contexts, stops following transportation
that reasonable suspicion exists when the officer violations must be reasonable in light of the
can point to specific and articulable facts which, circumstances. To reiterate, we hold only that the
taken together with rational inferences from those elapsed time between an observed violation and
facts, reasonably warrant the search and seizure. any subsequent stop must be reasonable upon
consideration of the totality of the circumstances.
Zuniga argues that the justifications supporting
the stop should not be considered, first, due to Because we conclude that the totality of the
staleness concerns regarding the turn-signal circumstances surrounding the turn-signal
offense and, second, because the parking violation provided the requisite reasonable
infraction was not confirmed until after the stop. suspicion to stop Zunigas vehicle, we need not
As for staleness, Zuniga suggests that we read decide whether the second traffic violation
Supreme Court precedent as mandating a provides an independent justification for the stop.
contemporaneity requirement in this context.
Admittedly, on the record before us, Zunigas Having determined there existed reasonable
staleness argument is not wholly devoid of suspicion to stop Zunigas vehicle, we now
support. The record indicates that the turn-signal consider whether the collective knowledge
offense occurred and was immediately relayed; doctrine provided the grounds for imputation of
yet, the call went unanswered by fellow officers. that information to Officer Pruit.
In fact, Zuniga was not stopped for this violation
until approximately fifteen minutes after it was Reasonable suspicion to stop a vehicle, or
observed. But other factors provide support for the probable cause to conduct a search, may arise
Governments argument that the stop was through the collective knowledge of the officers
reasonable. Notably, Zuniga does not dispute that involved in the operation. Under the collective
Detective Chavarria and other agents observed his knowledge doctrine, an officer initiating the stop
vehicle fail to signal continuously for at least 100 or conducting the search need not have personal
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