United States v. Dennis Dayton Holt
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Holt's officer safety reasoning continues to be cited favorably. All 47 flagged citations have been read; the confirmed treatments are listed below.
47 later cases cite United States v. Dennis Dayton Holt; 47 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. Dennis Dayton Holt?
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
Abrogated
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The Tenth Circuit held that Holt's restriction of permissible traffic stop questions to those specifically concerning loaded weapons was no longer good law after Muehler v. Mena.
United States v. Stewart · Tenth Circuit · filed
W e now make explicit what we implied in Alcaraz-Arellano and Wallace: in light of M uehler, the language from Holt approving traffic stop questions only when the officers specifically mention loaded weapons is no longer good law.
Read the full opinion on CourtListener →
Limited
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The Tenth Circuit held that Muehler limited Holt's rule requiring questions during a traffic stop to relate to the stop's initial purpose. Questions on other subjects do not violate the Fourth Amendment merely because of their content when they do not prolong the stop.
United States v. Alcaraz-Arellano · Tenth Circuit · filed
Although Holt held that further questioning is justifiable only if it is reasonable in relation to the initial purpose of the traffic stop ... the scope of this holding has been limited by the Supreme Court’s decision in Muehler v. Mena, 544 U.S. 93, 125 S. Ct. 1465 (2005).
Read the full opinion on CourtListener →
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