Brendlin v. California

Police stopped driver Karen Simeroth's car to check its permit, a stop the state later admitted was unfounded; an officer recognized passenger Bruce Brendlin (defendant) as a suspected parole violator, confirmed an outstanding warrant, and arrested him, finding drug paraphernalia on him and drugs in the car. Brendlin moved to suppress the evidence, arguing the initial stop was an unlawful seizure of him too, but the trial court ruled he was only seized once he was ordered out and arrested; the California Supreme Court affirmed, reasoning a passenger isn't seized during a stop directed at the driver.