Under both the Federal and the Maryland Constitutions, persons are protected against “unreasonable searches and seizures.” And this same rule applies to traffic stops, which are considered a form of “seizure” under applicable law. In general, this means that law enforcement officials cannot make a traffic stop or pull over a motorist without some reasonable basis for the traffic stop.

In Maryland, a recent court decision has held that a motorist crossing traffic and street lines can be the basis for a “reasonable” traffic stop. See Riley v. State, 342 A. 3d 430 (Md. Appellate Court 2025).

In the Riley case, the traffic stop involved a situation where a police officer observed a vehicle cross traffic lines and move into and over what is called a “gore area.” These gore areas are sharp areas bounded by white lines on roads and highways. The gore areas are often triangular in shape, but can come in other shapes. These are traffic control lines and areas where there might be a heightened road danger based on road contours and other roadside and geographic features.

In any event, in Riley, the defendant’s vehicle entered and crossed through one of these marked and lined “gore areas.” Thereafter, Maryland State Troopers pulled the vehicle over. The car contained a driver and three passengers. After a permissible “surface level” search of the vehicle, an unloaded gun was found, and then the driver and the three passengers were handcuffed.

On the question of whether the original traffic stop was “reasonable,” the Maryland courts held that the stop was reasonable. When a person or motorist is stopped where no warrant has been obtained from a judge, the rule is that the police officer must have some “articulable suspicion” for believing that a crime has been committed, is being committed, or will be committed in the near future.

In the Riley case, this legal rule was satisfied because the vehicle had crossed over into and driven through and over the gore area. According to the courts, this gave rise to a reasonable suspicion/belief that the car was being driven “contrary to the laws governing the operation of motor vehicles” under Maryland law.

Why the Riley case is important

The Riley case involved other legal questions, such as the reasonableness of the search that uncovered the unloaded gun and the reasonableness of handcuffing the driver and the passengers. However, putting aside those important legal matters, Riley is important as another reminder that violating traffic laws provides police officers with constitutional grounds for engaging in search and seizure activity. It seems that many drivers only vaguely think of traffic rules and regulations as LAWS. 

Let’s admit that traffic laws are often violated without consequence. However, when you are in Maryland, if you are violating those traffic laws, you can be pulled over, and the traffic stop will be deemed legally and constitutionally valid. From there, matters can become much worse. For example, maybe the police find drugs, weapons, or other illicit materials in the vehicle. Maybe the police have the basis for believing the person has been driving under the influence of alcohol or drugs.

Conclusion

Avoid violating traffic laws to avoid giving the police a legally valid reason for making a traffic stop.

Contact Waldorf, Maryland Criminal Defense Lawyer Robert Castro Today

This article has been provided by the Law Office of Robert Castro. For more information or questions, contact our office to speak to an experienced Maryland criminal defense lawyer at (301) 870-1200. We are Waldorf, MD, Criminal Defense lawyers. Our address is 11701 Central Avenue, Suite 200, Waldorf, MD 20601.