United States v. Guzman
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Tenth Circuit sitting en banc replaced Guzman's inquiry into whether a reasonable officer would have made the stop without an improper purpose. Its separate rule limiting further detention after a traffic stop remained intact and continued to be applied.
45 later cases cite United States v. Guzman; 45 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on United States v. Guzman?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The en banc Tenth Circuit overruled Guzman's pretext test for initial traffic stops and adopted a test based on an observed violation or reasonable suspicion of one.
United States v. Botero-Ospina · Tenth Circuit (en banc) · filed
Our sole inquiry is whether this particular officer had reasonable suspicion that this particular motorist violated “any one of the multitude of applicable traffic and equipment regulations” of the jurisdiction. Delaware v. Prouse, 440 U.S. 648, 661, 99 S.Ct. 1391, 1400, 59 L.Ed.2d 660 (1979). To the extent that our decision in United States v. Guzman, 864 F.2d 1512 (10th Cir.1988), is inconsistent with this holding, it is overruled.
Read the full opinion on CourtListener →
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