This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
Background and question before the Court
According to Joseph L. Parkhurst (Petitioner), according to Joseph L. Parkhurst (Petitioner), the case concerns whether a pat‑down (frisk) of a vehicle passenger after a lawful traffic stop is permissible under the principles established in Pennsylvania v. Mimms and related precedent.
According to Justice Kennedy, the Court is asked to decide whether Officer Trevizo had reasonable suspicion that the passenger, Johnson, was armed and dangerous at the time of the frisk.
What each side argues
Petitioner (Arizona)
According to Joseph L. Parkhurst (Petitioner), according to Joseph L. Parkhurst (Petitioner), petitioner asks the Court to apply Mimms, holding that a traffic stop satisfies the first prong of Terry and that a pat‑down of a driver is justified when the officer has reasonable suspicion the driver is armed and dangerous.
Petitioner contends that Officer Trevizo did not have reasonable suspicion that Johnson was armed and dangerous.
Amicus Curiae (United States)
According to Mr. Heytens, the amicus further states that a reasonable person would understand they are not free to leave a stopped car until the officer clearly indicates the seizure is over.
Respondent (Lemon Montrea Johnson)
Source-limited. The record does not yet support a complete account.
What happened at oral argument
Justice Kennedy asked whether the petitioner said that Mimms established it was likely the passenger was armed and dangerous.
Chief Justice Roberts asked whether there is a point in a traffic stop where the interaction changes from a seizure to a consensual encounter.
Justice Stevens asked whether a roadside encounter for a flat‑tire change that leads an officer to suspect the driver is armed permits a search.
According to Justice Ginsburg, justice Ginsburg questioned whether the officer’s conduct falls under the “Mind if I search your luggage” line of cases.
Justice Scalia asked whether allowing the pat‑down would extend to other kinds of seizures such as roadblocks for drunken‑driving checks.
Justice Kennedy asked whether the petitioner concedes that Officer Trevizo had reasonable suspicion that Johnson was armed and dangerous.
Justice Stevens asked whether the petitioner argues that Johnson was not dangerous.
- [1] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 4
- [2] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 4
- [3] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 21
- [4] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 39
- [5] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 54
- [6] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 56
- [7] 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdf, p. 58
What the Court decided
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 21fada24387e690f9356-r1-81f57b4e35a91ef5.pdforal argument transcript
Guide generated September 22, 2026. Automated validation accepted this version.