Probable cause for traffic stop; People v Kavanaugh; Objective-reasonableness standard; Whren v United States; Vehicle lacking valid insurance; MCL 500.3102(2); Ordering a driver out; Pennsylvania v Mimms; Protective search of the passenger compartment; Michigan v Long; Extension of stop; People v Williams; Second Amendment argument; CPL requirement for pistols in vehicles; MCL 750.227; People v Langston

The court held that the firearm discovered under the driver’s seat was admissible because the vehicle search fell within Long and the stop was otherwise lawful. Officers ran defendant’s plate at a gas station. When LEIN showed no insurance, they lawfully stopped the car. After ordering defendant out, an officer saw an empty holster on defendant’s waist. Defendant then said a registered gun was “where it was supposed to be” in the car but did not produce a CPL. On these facts, the trial court denied his motion to suppress. On appeal, the court rejected defendant’s argument that the search was premised on marijuana transport rules, noting “‘[s]ubjective intentions play no role,’” and an officer’s action is valid “‘so long as the circumstances, viewed objectively, justify that action.’” Given the empty holster and statement about a gun in the car, the officers had a reasonable belief defendant was dangerous and “‘may gain immediate control of weapons,’” authorizing a limited search of areas “‘in which a weapon may be placed or hidden[.]’” The search under the driver’s seat fit Long and did not impermissibly extend the stop because a “‘new set of circumstances’” justified the brief expansion under Williams. Finally, the court rejected the Second Amendment claim, noting it has held the requirement “‘that a person must possess a valid CPL in order to carry a pistol in an automobile does not violate the Second Amendment.’” Affirmed.