Maryland High Court Rules on Traffic Stops for Cell Phone Use

The Supreme Court of Maryland has clarified the standard police officers must meet to justify a traffic stop when observing a driver manipulating a mobile phone. According to the court’s ruling in State of Maryland v. Michael Eugene Stone, officers must have specific, articulable facts that reasonably indicate a violation of traffic laws related to mobile phone use has occurred or is occurring. Simply observing a driver touching or pressing a phone screen is not enough, on its own, to establish reasonable suspicion for a stop.

The ruling stems from the case of Michael Eugene Stone, who was stopped by Hagerstown police officers who observed him manipulating his cell phone while driving. While the officers initially stated it appeared he was typing a message or placing a call, the court found this observation, without further corroborating details, did not meet the threshold for reasonable suspicion. The state argued that the conduct was consistent with illegal mobile phone use, and police should be allowed to investigate further to resolve any ambiguity. However, the court determined that such observations are equally consistent with lawful uses of a phone, such as using GPS, making or ending a call, or operating the device’s basic functions. These lawful uses are common among drivers and do not narrow down the possibilities to a degree that suggests specific wrongdoing.

The court emphasized that a traffic stop is a detention protected by the Fourth Amendment, requiring officers to have a particularized and objective basis for suspecting illegal activity. This standard requires more than a general observation that could apply to a large portion of law-abiding drivers. The court referenced numerous previous rulings, including those from the U.S. Supreme Court, which mandate that officers must be able to point to specific facts and rational inferences that lead to a reasonable belief that a traffic law violation has occurred or may be occurring.

In Stone’s case, the officers’ observations were deemed “innocuous behavior” that did not exclude a substantial number of innocent drivers. The court reasoned that while the state has a significant interest in preventing distracted driving, the Fourth Amendment’s protection against unreasonable seizures means that traffic stops cannot be based on mere hunches or generalized suspicions. The ruling reversed the circuit court’s decision, which had allowed the stop based on the reasoning that observing phone manipulation is sufficient suspicion in today’s world where texting is prevalent.

This decision impacts how law enforcement officers in Maryland can initiate traffic stops related to cell phone use. Drivers who are using their phones for permitted activities, such as navigation or briefly operating the device, may not be subject to stops based solely on the visual observation of them interacting with their phones. The court stressed that while officers are not required to definitively prove a violation at the point of a stop, their observations must provide more than just a possibility of illegal activity.

Article by Mel Anara, based upon information from the Supreme Court of Maryland.

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