Wright v. State

Tramon Wright v. State of Maryland, No. 2391, September Term, 2024 Opinion by Zic, J. AUTOMOBILES – VIOLATION OF VEHICULAR LAWS – IMPEDING THE NORMAL AND REASONABLE MOVEMENT OF TRAFFIC Md. Code, Transportation, § 21-804(a) disallows any person from willfully driving at such a slow speed as to impede the normal and reasonable movement of traffic. We hold that § 21-804(a) applies to vehicles that are completely stopped in a lane of traffic such that they impede the normal and reasonable movement of traffic. Where a vehicle is completely stopped in a traffic lane at a steady green light, thus causing multiple vehicles to maneuver around it, the driver has impeded the normal and reasonable movement of traffic in violation of § 21-804(a). CRIMINAL LAW – SEARCHES AND SEIZURES – REASONABLE SUSPICION Law enforcement had reasonable suspicion to effectuate a traffic stop of the vehicle in which Appellant was a passenger based on a suspected violation of Md. Code, Transportation, § 21-804(a), where the evidence showed that the vehicle was stopped at a green light, thus blocking the center lane and requiring other vehicles to change lanes in order to continue on through the intersection. Circuit Court for Baltimore City Case No. C-24-CR-24-002677 REPORTED IN THE APPELLATE COURT OF MARYLAND No. 2391 September Term, 2024 ______________________________________ TRAMON WRIGHT v. STATE OF MARYLAND ______________________________________ Shaw, Zic, Eyler, Deborah S. (Senior Judge, Specially Assigned), JJ. ______________________________________ Opinion by Zic, J. ______________________________________ Filed: October 30, 2026 Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic. 2026.10.30 '00'04- 15:16:03 Gregory Hilton, Clerk  In October 2024, Tramon Wright, appellant, was charged in the District Court of Maryland for Baltimore City with various firearm offenses. The charges arose from the discovery of a handgun during a traffic stop and search of a vehicle in which Mr. Wright was a passenger. Mr. Wright demanded a jury trial, and the case was transferred to the Circuit Court for Baltimore City. He subsequently moved to suppress evidence of the firearm as the product of an unlawful stop and search. After the court denied that motion, Mr. Wright entered a conditional guilty plea to one count of wearing, carrying, and transporting a loaded handgun in a vehicle.1 The court sentenced him to five years’ incarceration, with all but one year suspended, to be followed by three years of probation. On appeal, Mr. Wright presents one question for our review, which we have recast as two: 1. Did the circuit court err in determining that the police had reasonable articulable suspicion to initiate the traffic stop? 2. Did the circuit court err in concluding that Mr. Wright lacked standing to challenge the admissibility of the handgun?2 For the reasons that follow, we shall order a limited remand for further proceedings consistent with this opinion. 1 The written conditional guilty plea preserved Mr. Wright’s right to appeal “the issue litigated at the pre-trial motions hearing and contained in the motion submitted to the [c]ourt.” 2 Mr. Wright phrased the question as follows: “Did the circuit court err in denying the motion to suppress?”  BACKGROUND Underlying Facts3 At approximately 9:45 p.m. on October 3, 2024, Baltimore City Police Detective Larson was monitoring the feed from a camera located at 800 Abbott Court when he observed Mr. Wright carrying “a brown . . . designer satchel bag.”4 Approximately five minutes later, Detective Larson watched Mr. Wright “get into the front passenger seat of a gray . . . Honda Crosstour” parked in the 900 block of Hillman Street. Mr. Wright was accompanied by a man later identified as Kent Adams, whom Detective Larson observed get into the Crosstour’s driver’s seat and drive away. Detective Larson radioed a description of the men, the vehicle, and their direction of travel to a team of four officers riding in an unmarked Ford Fusion. The Fusion was driven by Detective Scott and occupied by Detectives Jones and Kemerer, as well as Sergeant Cucchiaro. The officers followed the Crosstour to the intersection of Harford Avenue and East Chase Street, where they observed it “sit completely stopped in a traffic 3 Because Mr. Wright challenges only the circuit court’s denial of his motion to suppress, we will limit our recitation of the facts to those adduced at the suppression hearing. See Washington v. State, 482 Md. 395, 420 (2022) (“When reviewing a trial court’s denial of a motion to suppress, we are limited to information in the record of the suppression hearing[.]”). Although neither party called any witnesses to testify at that hearing, Mr. Wright did introduce into evidence the statement of probable cause authored by Detective Michael Kemerer, one of the arresting officers. Accordingly, our recitation of the underlying facts is based exclusively on the representations contained in that document. 4 Aside from Detective Kemerer, the record does not disclose the first names of any of the relevant police officers. 2 lane at a steady green light in a manner that obstructed the free flow of northbound traffic in the middle lane of Harford Ave.” According to Detective Kemerer, the Crosstour “obstructed traffic for an extended period of time[,]” during which “multiple vehicles drove past” it. The Crosstour “eventually continued travelling northbound on Harford Ave[.]” After the vehicle entered the 1100 block of Harford Avenue, Detective Scott activated the vehicle’s emergency equipment and initiated a traffic stop of the Crosstour at the intersection of Harford Avenue and East Biddle Street. As the officers exited the Fusion and approached the Crosstour, Detective Kemerer observed the vehicle “inch forward multiple times, indicating [it] was still in drive.” By the time Mr. Adams brought the Crosstour to a complete stop and put it in park, the officers were positioned on either side of the vehicle with a clear view of its interior. From the rear passenger side of the Crosstour, Detective Kemerer observed the brown satchel Mr. Wright had been carrying “on the driver’s side rear floor[]board.” He further noted that the driver’s seat appeared to be fully reclined “in what seemed to be an attempt to conceal the . . . satchel[.]” Meanwhile, Detective Scott spoke with Mr. Adams at the driver’s window. Detective Scott explained the reason for the stop and directed Mr. Adams to produce his driver’s license and registration. According to Detective Kemerer, although Mr. Adams handed Detective Scott his driver’s license, he “seemed to be nervous and hesitant to reach around the passenger compartment to find [his] registration.” 3  Suspecting that the Crosstour might contain narcotics or firearms, Detective Scott called for a K-9 unit before asking Mr. Adams to exit the vehicle. Although Mr. Adams initially complied with the request and began walking toward the rear of the vehicle, he then fled on foot. Detectives Scott and Jones gave chase, while Sergeant Cucchiaro and Detective Kemerer remained with Mr. Wright, who was still inside the Crosstour. Detective Kemerer “then removed [Mr.] Wright from the vehicle” and “place[d] him in handcuffs[,] fearing he was also a flight risk” and suspecting that the Crosstour might contain incriminating evidence. After arresting Mr. Adams, Detective Scott returned to the Crosstour and conducted what Detective Kemerer characterized as an inventory search of the vehicle.5 Inside the brown satchel, Detective Scott found a “Glock 23 Gen 5 .40 caliber handgun . . . loaded with 21 live .40 caliber cartridges[.]” Detective Scott then recovered a second loaded handgun lying partly beneath the driver’s seat and partly beneath “the removable carpet located on the front driver’s side floor[]board[.]” After Detective Scott had rendered the firearms safe, Detective Kemerer “placed [Mr. Wright] under arrest[.]” Mr. Adams was issued three citations, including one for impeding the normal and reasonable movement of traffic. At the time of his arrest, Mr. Wright was prohibited from possessing a regulated firearm because (1) he was under the age of 21 and (2) he had been adjudicated delinquent as a juvenile for an act that would 5 In his statement of probable cause, Detective Kemerer claimed that because Mr. Adams had been “arrested for fleeing and eluding,” the search of the vehicle also constituted a search incident to his arrest. 4 have been a disqualifying crime if committed by an adult. See Md. Code Ann., Pub. Safety § 5-133(b)(15), (d)(1) (2003, 2022 Repl. Vol., Supp. 2024). Pertinent Procedural History On January 17, 2025, Mr. Wright filed a motion to suppress the Glock 23 handgun as the fruit of an unlawful stop and search. He presented three arguments in support of that motion. First, Mr. Wright contended that the detectives lacked probable cause to effectuate the traffic stop. Specifically, he asserted that the conduct described in the statement of probable cause did not establish that Mr. Adams had driven so slowly as to impede the normal and reasonable movement of traffic in violation of Maryland Code Annotated, Transportation (“TR”) § 21-804(a) (1977, 2020 Repl. Vol.) . He also noted that the State subsequently dismissed the citation issued under that provision. Second, Mr. Wright challenged the search of the Crosstour on the ground that it could not be justified either under the automobile exception to the warrant requirement or as a search incident to Mr. Adams’ arrest. Finally, Mr. Wright argued that the search of the vehicle was not a valid inventory search because it had not been conducted in accordance with Baltimore City Police Department policies and procedures. The circuit court held a hearing on Mr. Wright’s motion the same day it was filed. With respect to Mr. Wright’s challenge to the traffic stop, the State asserted that its discretionary dismissal of the traffic citation had no bearing on whether the detectives had a lawful basis for the stop at its inception. As to the warrantless search of the 5 vehicle, the State argued that because Mr. Wright was a passenger in the Crosstour and not its registered owner, he lacked standing to challenge the legality of the search. With respect to standing, defense counsel responded that because Mr. Wright was a passenger in the Crosstour when police stopped it, he was seized for Fourth Amendment purposes and was therefore entitled to challenge the constitutionality of the stop. When the court asked whether Mr. Wright’s standing argument concerned the stop, counsel answered in the affirmative. Counsel then reiterated her position that the detectives lacked probable cause to initiate the traffic stop, asserting that the conduct described in the statement of probable cause did not correspond to the traffic infraction for which Mr. Adams was cited. Specifically, counsel argued that although TR § 21-804(a) prohibits driving at such a slow speed as to impede the normal and reasonable movement of traffic, the statement of probable cause described Mr. Adams as having remained stopped after a traffic light turned green while other vehicles passed. According to the defense, that discrepancy demonstrated that the cited infraction did not supply a lawful basis for the stop. Turning to the search of the Crosstour, defense counsel asserted that neither the automobile exception nor the search incident to arrest exception justified the warrantless search of the vehicle. With respect to the automobile exception, she argued that the evidence before the court did not establish probable cause to believe the vehicle contained evidence related to the alleged traffic infraction underlying the stop. As to the latter theory, counsel maintained that the timing of the search relative to Mr. Adams’ 6 arrest was inconsistent with the application of the search incident to arrest exception. Accordingly, the defense argued, the State failed to establish a basis for the warrantless search under either rationale. Finally, defense counsel maintained that the search of the Crosstour was not a valid inventory search. In support of that position, counsel cited Baltimore City Police Department Policy 902, which, she asserted, prohibited officers from inventorying a vehicle seized as evidence until it had been “lawfully and reasonably impounded[,]” a condition that had not been satisfied at the time of the search. Counsel further claimed that the search had been conducted for investigatory—rather than inventory—purposes. In its rebuttal, the State argued that Mr. Wright had failed to meet his burden of proving he had a reasonable expectation of privacy and he, therefore, lacked standing to challenge the warrantless search. The State then emphasized that the officers needed only reasonable suspicion to effectuate the traffic stop, rather than probable cause, as defense counsel had suggested. Finally, it asserted that the officers had reasonably suspected that Mr. Adams violated TR § 21-804(a), arguing that “driving at zero miles per hour in the middle of a roadway” amounted to “driving slow enough to impede the reasonable flow of traffic.” After hearing oral argument, the circuit court announced its ruling from the bench. With respect to the traffic stop, the court first found that the Crosstour had remained stopped at a green light, causing “several vehicles . . . to drive around” it “in order to continue the free flow of traffic.” It then determined that the citation issued to Mr. Adams 7 under TR § 21-804(a) was appropriate, reasoning that the evidence indicated that the vehicle had “imped[ed] the reasonable[,] normal movement of traffic” by “moving at such a slow speed, zero . . . miles per hour[,] at a green light[.]” The circuit court did not reach the merits of Mr. Wright’s remaining challenges to the warrantless search of the Crosstour. Instead, it ruled that Mr. Wright lacked standing to challenge the search, reasoning: As to standing, [Mr. Wright] must show lawful ownership interest or lawful possessory interest in the premises to be searched or a reasonable expectation of privacy in the area from which items were seized. In this case, there’s no information before the [c]ourt that [Mr. Wright] had any lawful interest or any lawful possessory interest in the premises that was searched, the vehicle. . . . He was not the driver; he was the passenger. There’s no information, subjective or objective, to show that he had a reasonable expectation of privacy in that vehicle that was searched. So[,] therefore, this [c]ourt finds that [Mr. Wright] does not have standing to challenge the search of the vehicle. Consistent with these conclusions, the court denied Mr. Wright’s motion to suppress. DISCUSSION I. THE COURT DID NOT ERR IN DETERMINING THAT THE POLICE HAD REASONABLE SUSPICION TO CONDUCT A TRAFFIC STOP OF THE CROSSTOUR. A. Parties’ Contentions Mr. Wright contends that the circuit court erred in determining that the Crosstour had “impede[d] the normal and reasonable movement of traffic” for purposes of 8 TR § 21-804(a). He argues that, even when viewed in the light most favorable to the State, the evidence was insufficient to establish that the detectives had reasonable suspicion—much less probable cause—to believe that Mr. Adams had violated that provision. The State responds that the evidence supported a reasonable suspicion that Mr. Adams had violated TR § 21-804(a), as it showed that the Crosstour was stopped at a green light, thereby blocking the center lane and requiring other vehicles “to change lanes in order to continue on through the intersection.” It further asserts that “Mr. Adams’[] failure to proceed through the intersection when the traffic signal turned green amounted to a failure to obey a traffic control device under TR § 21-201(a)(1)[,]” thereby supplying an independent basis for the stop.6 Alternatively, the State argues that “[e]ven if the stationary vehicle did not violate the traffic law,” the traffic stop remained valid because it was “based on an objectively reasonable mistake of law.” B. Standard of Review When reviewing the denial of a motion to suppress, “we view the evidence presented at the [suppression] hearing, along with any reasonable inferences drawable therefrom, in a light most favorable to the prevailing party[,]” here, the State. Davis v. State, 426 Md. 211, 219 (2012). Accordingly, we will “accept the circuit court’s findings 6 TR § 21-201(a)(1) states: “Subject to the exceptions granted in this title to the driver of an emergency vehicle, the driver of any vehicle, unless otherwise directed by a police officer, shall obey the instructions of any traffic control device applicable to the vehicle and placed in accordance with the Maryland Vehicle Law.” 9 of fact unless clearly erroneous[.]” Founds v. State, ___ Md. ___, No. 48, Sept. Term, 2025, 2026 WL 2279983 (filed Aug. 7, 2026). “A finding is clearly erroneous when . . . the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed.” Kusi v. State, 438 Md. 362, 383 (2014) (quotation marks and citation omitted). We will therefore “defer to the [court’s] fact-findings . . . whenever there is some competent evidence which, if believed and given maximum weight, could support such findings of fact.” Morris v. State, 153 Md. App. 480, 489 (2003). Although we defer to the circuit court’s factual findings unless clearly erroneous, “we review de novo the ‘court’s application of the law to its findings of fact.’” Pacheco v. State, 465 Md. 311, 319 (2019) (quoting Norman v. State, 452 Md. 373, 386 (2017)). Thus, “‘[t]he ultimate determination of whether there was a constitutional violation . . . is an independent determination that is made by the appellate court alone, applying the law to the facts found in each particular case.’” State v. Carter, 472 Md. 36, 55 (2021) (quoting Belote v. State, 411 Md. 104, 120 (2009)). C. Fourth Amendment Principles The Fourth Amendment to the United States Constitution, made applicable to the states by the Fourteenth Amendment, “protects ‘[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.’” State v. Johnson, 458 Md. 519, 533 (2018) (quoting U.S. Const. amend. IV). “‘A police- initiated traffic stop constitutes a seizure within the confines of the Fourth 10 Amendment[,]’” and is therefore subject to its reasonableness requirement. Riley v. State, 266 Md. App. 598, 615 (2025) (quoting Spell v. State, 239 Md. App. 495, 507 (2018)). “A traffic stop is reasonable under the Fourth Amendment if it is based on reasonable articulable suspicion to believe that the vehicle was being driven contrary to the laws governing the operation of motor vehicles.” Id. (citation modified); see also State v. Williams, 401 Md. 676, 690-91 (2007). Reasonable suspicion refers to “‘a particularized and objective basis for suspecting the particular person stopped’ of breaking the law.” Heien v. North Carolina, 574 U.S. 54, 60 (2014) (quoting Navarette v. California, 572 U.S. 393, 396 (2014)). The standard “exists somewhere between unparticularized suspicions and probable cause.” Sizer v. State, 456 Md. 350, 364 (2017). In assessing whether reasonable suspicion justified a traffic stop, “a court must consider ‘the totality of the circumstances—the whole picture.’” McDowell v. State, 407 Md. 327, 337 (2009) (quoting United States v. Sokolow, 490 U.S. 1, 8 (1989)). “[T]he standard for ‘reasonable suspicion’ is intentionally fluid because it ‘is not readily, or even usefully, reduced to a neat set of legal rules.’” Trott v. State, 473 Md. 245, 257 (2021) (quoting Sokolow, 490 U.S. at 7). Rather, it is “a common sense, nontechnical conception that considers factual and practical aspects of daily life and how reasonable and prudent people act.” Stokes v. State, 362 Md. 407, 415 (2001). 11  D. Analysis 1. The Challenged Factual Finding Was Not Clearly Erroneous. Mr. Wright’s contention that the detectives lacked reasonable suspicion to stop the Crosstour rests, in part, on a challenge to the circuit court’s finding that “‘the car was stopped at the green light,’ such that ‘several vehicles had to drive around [it] in order to continue the free flow of traffic.’” He argues that this finding “is not supported by the evidence[,]” because the statement of probable cause indicated only that “‘multiple vehicles drove past [the Crosstour] during th[at] time . . . ,’ not that ‘multiple vehicles drove around said vehicle.’” We are not persuaded. Although the statement of probable cause did not expressly state that “multiple vehicles drove around” the Crosstour, the circuit court was entitled to draw reasonable inferences from the facts described rather than limit its analysis to the statement’s precise wording. As discussed above, the statement of probable cause reported that the detectives observed the Crosstour “sit completely stopped in a traffic lane at a steady green light in a manner that obstructed the free flow of northbound traffic in the middle lane of Harford Ave.” (Emphasis added). It further stated that the Crosstour “obstructed traffic for an extended period of time and multiple vehicles drove past said vehicle during that period of time.” (Emphasis added). Those circumstances supported a reasonable inference that the vehicles that drove past the stopped Crosstour did so by maneuvering around it. Mr. Wright’s alternative interpretation of the statement 12 of probable cause does not render the court’s inference unreasonable or the resulting finding clearly erroneous. 2. The Detectives Had Reasonable Suspicion to Stop the Crosstour. Having resolved Mr. Wright’s factual challenge, we turn to whether the circumstances furnished the detectives with reasonable suspicion that Mr. Adams violated TR § 21-804(a). That subsection states: “Unless reduced speed is necessary for the safe operation of the vehicle or otherwise is in compliance with law, a person may not willfully drive a motor vehicle at such a slow speed as to impede the normal and reasonable movement of traffic.” TR § 21-804(a). Although the Transportation Article does not include a definition of “impede,” the Oxford English Dictionary defines the term as “[t]o retard in progress or action by putting obstacles in the way; to obstruct; to hinder; to stand in the way of.” Impede, Oxford English Dictionary (Oxford University Press 2026), https://perma.cc/AS2W-5GW3; see also Schreyer v. Chaplain, 416 Md. 94, 101 (2010) (explaining that we may “consult the dictionary to elucidate terms that are not defined in the statute” (quotation marks and citation omitted)). Thus, to impede traffic, a driver need not prevent its progress altogether. A lesser interference—whether by obstruction, hindrance, or delay—may also suffice. Mr. Wright does not dispute that Mr. Adams was willfully “driving” the Crosstour at “a slow speed” for purposes of TR § 21-804(a). Nor does he invoke the provision’s exception for reduced speed that is “necessary for the safe operation of the vehicle or otherwise is in compliance with law[.]” TR § 21-804(a). Accordingly, we need not 13 consider either issue. See Diallo v. State, 413 Md. 678, 692 (2010) (“Arguments not presented in a brief or not presented with particularity will not be considered on appeal.” (citation modified)). Instead, Mr. Wright contends only that the circumstances did not give rise to reasonable suspicion that the Crosstour was “imped[ing] the normal and reasonable movement of traffic.” TR § 21-804(a). In support of that contention, he emphasizes that “there is no evidence of either a maximum or minimum speed limit, what the ‘normal and reasonable flow of traffic’ is at the intersection [of] Harford Ave. and Chase St., or how long the vehicle was stopped at the green light.” He further argues that Detective Kemerer’s assertion in the statement of probable cause that the Crosstour “was stopped ‘for an extended period of time’ is not sufficiently specific to conclude that the vehicle was ‘truly impeding traffic[.]’” (Citation omitted). Posted speed limits and the typical pace of traffic in a particular area may be probative of whether a vehicle is being driven so slowly as to impede the normal and reasonable movement of traffic. Those factors are less significant, however, where, as here, the subject vehicle was completely stopped in an active travel lane. Indeed, of the various out-of-state opinions Mr. Wright cites in support of his position, only People v. Martinez, 31 Misc. 3d 201 (Nassau Dist. Ct. 2011), involved the traffic stop of a vehicle that was stationary in a lane of traffic. In Martinez, a New York trial court considered whether an officer had probable cause to stop the defendant’s vehicle for violating a comparable state statute prohibiting driving “‘at such a slow speed as to impede the normal and reasonable movement of 14 traffic[.]’” Id. at 205 (quoting N.Y. Veh. & Traf. Law § 1181). The defendant in that case remained stopped for approximately 30 seconds after a traffic light turned green. Id. at 203. “[W]ithin seconds of the light turning green[,]” two vehicles behind the defendant “moved around [his vehicle] and proceeded on their way, without any apparent difficulty.” Id. at 205-06. When the light turned yellow, the defendant made a lawful left turn. Id. at 203. The trial court concluded that those circumstances did not provide the officer with probable cause to believe that the defendant had violated the impeding traffic statute and therefore suppressed the evidence obtained following the stop. Id. at 206-07. In so ruling, the court reasoned that “the [d]efendant’s conduct, in merely waiting for the traffic light to turn yellow before making a lawful left[-]hand turn” did not “interfer[e] with the reasonable progress of the other motorists present or creat[e] a danger of any kind to any motorist.” Id. Preliminarily, we note that Martinez is an out-of-state trial court decision and, as such, is “not binding precedent on any court.” Bunch v. Robinson, 122 Md. App. 437, 453 (1998), rev’d sub nom. on other grounds, Robinson v. Bunch, 367 Md. 432 (2002). Accordingly, if the rationale underlying the court’s ruling “fails to persuade, [it is] no authority at all.” Wagner v. State, 220 Md. App. 174, 193 n.18 (2014) (quotation marks and citation omitted), aff’d, 445 Md. 404 (2015). To the extent that Martinez treated other motorists’ ability to proceed around a stationary vehicle without apparent difficulty as indicating that the normal and reasonable movement of traffic had not been impeded, 15 we are not persuaded by the court’s reasoning.7 Rather, consistent with the ordinary meaning of “impede,” we conclude that the need for motorists to maneuver around a vehicle stopped in an active travel lane may itself demonstrate an obstruction and hindrance of normal and reasonable flow of traffic. On that point, we find State v. Carson instructive. 404 P.3d 1017 (Or. Ct. App. 2017). In Carson, a police officer drove up behind the defendant’s car, “which was completely stopped in the right lane” of a two-lane, one-way street “just before an intersection[,]” where there was neither a traffic light nor a stop sign. Id. at 1018. Although the officer could have proceeded around the defendant’s vehicle in the left lane, he “instead pulled up behind the car and waited for approximately five seconds” before his partner sounded the horn. Id. When the vehicle did not move after “another few seconds,” the officer activated his emergency lights, approached the driver’s side window, and ultimately arrested the defendant for driving under the influence. Id. The defendant later moved to suppress evidence arising from the stop, arguing that the officer lacked probable cause to believe that he had violated Oregon Rev. Stat. (“ORS”) § 811.130(1), which provides: “A person commits the offense of impeding traffic if the 7 The trial court’s ruling in Martinez also rested, at least in part, on an interpretation of the relevant traffic statute as requiring that a vehicle’s slow rate of speed “create[] a clear, present and real danger” to other motorists. Martinez, 31 Misc. 3d at 205 (quotation marks and citations omitted). TR § 21-804(a) does not expressly include such a requirement, and we decline to read one into that provision. See Allen v. State, 440 Md. 643, 671 (2014) (“We will not read into the statute words that give it an interpretation that limits or extends its application beyond the words the Legislature used.” (citation modified)). 16 person drives a motor vehicle . . . in a manner that impedes or blocks the normal and reasonable movement of traffic.” Carson, 404 P.3d at 1019. The trial court denied that motion. Id. On appeal, the defendant maintained that the traffic stop was unsupported by probable cause “because his conduct did not violate ORS 811.130.” Id. Specifically, the defendant argued that “his stopping did not impede or block [the officer’s] passage, or that of any other vehicle,” as the officer “could have moved to the left lane and continued on[.]” Id. at 1020. The Oregon Court of Appeals disagreed, holding that probable cause supported the stop because the defendant’s conduct violated ORS § 811.130. Id. at 1021. The court reasoned: [D]efendant impeded or blocked the normal and reasonable movement of traffic because he effectively converted a two- lane road into a single-lane road, and, if [the officer] had wished to proceed past defendant, he would have been required to change lanes to do so. The “normal and reasonable” movement of traffic here would be that vehicles in each lane could proceed in their respective lanes of travel and not have to switch lanes due to a car blocking traffic in one of them. Therefore, defendant’s conduct altered the normal flow of traffic. Id. (Emphasis added). Although ORS § 811.130(1) differs slightly from TR § 21-804(a), Carson remains instructive insofar as it held that a vehicle stopped in a travel lane may impede the normal and reasonable movement of traffic by inducing other vehicles to leave their respective lanes to maneuver around it. Id. That holding is consistent with the decisions of other 17 state appellate courts applying comparable statutes to vehicles stopped in travel lanes. See Smith v. State, 791 S.E.2d 418, 420-21 (Ga. Ct. App. 2016) (holding that an officer had reasonable suspicion to stop appellant’s vehicle for impeding “the normal and reasonable movement of traffic,” where the vehicle stopped at “a green traffic light on a highway for no apparent reason, forcing traffic to maneuver around him”); Wilkes v. Comm’r of Pub. Safety, 777 N.W.2d 239, 241, 243-44 (Minn. Ct. App. 2010) (holding that an officer had an objective basis to stop appellant’s car for impeding the normal and reasonable movement of traffic where the vehicle was stopped in a travel lane and caused the officer to reduce his speed, notwithstanding an open adjacent lane and the absence of “vehicles piled up behind appellant”); Green v. State, 773 S.W.2d 816, 817-18 (Tex. App. 1989) (holding that probable cause supported the stop of appellant’s vehicle for impeding traffic where he remained stopped for two to four minutes on a two-lane street, blocking the southbound lane and forcing three or four vehicles to steer around him). Consistent with these authorities, we are persuaded that a vehicle may impede the normal and reasonable movement of traffic by remaining stationary in an active travel lane and requiring motorists to maneuver around it. Here, the Crosstour remained stopped in the middle travel lane at a green light while several motorists drove around it to continue on Harford Avenue. Their ability to bypass the Crosstour did not negate the impediment. Rather, by remaining stopped in the middle travel lane, the Crosstour obstructed the ordinary use of that lane and required motorists to maneuver around the vehicle to proceed northbound. Those circumstances provided an objective basis for 18 suspecting that the Crosstour was impeding the normal and reasonable movement of traffic. The absence of evidence establishing precisely how long the Crosstour remained stopped does not compel a different result. The statement of probable cause described the Crosstour as obstructing traffic for an “extended period of time[.]” Although that description does not specify the duration of the obstruction, it indicated more than a momentary delay. On these facts, therefore, we are persuaded that the statement of probable cause supported a reasonable suspicion that Mr. Adams had violated TR § 21-804(a). Having resolved the issue on that ground, we need not address the State’s alternative arguments that the stop was independently justified under TR § 21- 201(a)(1) or by an objectively reasonable mistake of law. II. THE COURT’S STANDING RULING DID NOT RESOLVE WHETHER MR. WRIGHT HAD A REASONABLE EXPECTATION OF PRIVACY IN THE SATCHEL. A. Parties’ Contentions Mr. Wright also contends that “the circuit court erred in determining that he lacked standing to challenge the admissibility of the handgun recovered from the satchel.” In support, Mr. Wright argues that, regardless of whether he had a reasonable expectation of privacy in the vehicle, the court was required to assess whether he had such an expectation in the satchel from which the handgun at issue was recovered. The State concedes that the circuit court should have addressed whether Mr. Wright had a reasonable expectation of privacy in the satchel but failed to do so. 19 Accordingly, it agrees that we “should remand the case . . . for a supplemental hearing on the validity of the officers’ search of the satchel.” B. Fourth Amendment Standing “Standing is the ‘threshold question of the entitlement to litigate the merits of the search and seizure.’” White v. State, 248 Md. App. 67, 88 (2020) (quoting Bates v. State, 64 Md. App. 279, 282 (1985)); see also State v. Savage, 170 Md. App. 149, 174 (2006) (“Far from reaching the Fourth Amendment merits, standing settles only the entitlement to litigate those merits.”). “[T]o enjoy Fourth Amendment standing, a defendant must have both (1) an actual subjective expectation of privacy; and (2) an expectation that is objectively reasonable.” Savage, 170 Md. App. at 182. With respect to the second prong, the Supreme Court of the United States has made clear that a mere passenger in an automobile—who asserts “neither a property nor a possessory interest” therein—does “not normally have a legitimate expectation of privacy” in the vehicle for Fourth Amendment purposes. Rakas v. Illinois, 439 U.S. 128, 148-49 (1978). See also Savage, 170 Md. App. at 187 (explaining that the Rakas petitioners’ “status as mere, albeit legitimate, passengers did not give them standing to litigate the warrantless search of the automobile”); Jones v. State, 42 Md. App. 209, 214 n.2 (1979) (“[A]s a passenger in the car[,] the appellant would lack standing to complain under Rakas[.]”). Although a mere passenger ordinarily lacks standing to challenge the search of an automobile itself, that does not foreclose a challenge to the search of a container within the vehicle, provided the passenger has a reasonable expectation of privacy in it. Both 20 parties cite Owens v. State, 322 Md. 616 (1991), in support of this principle, and we agree that the case is instructive. There, Owens left a closed nylon bag in the apartment of Marla Gardin, a friend with whom he had been staying. Id. at 618. Although Gardin had allowed Owens to leave the bag in her home, Owens had not given her permission to open it. Id. at 618-19. After Owens had gone, the police came to the apartment and, with Gardin’s consent, searched the premises. Id. at 620. During that search, the officers opened Owens’ bag and discovered contraband inside. Id. at 621. Following his arrest, Owens moved to suppress the fruits of that search. Id. at 618. The circuit court denied that motion on the ground that Owens lacked standing to challenge the search. Id. at 624. On appeal, the Supreme Court of Maryland reversed Owens’s conviction, holding that, although he “had no legitimate expectation of privacy in the apartme