State v. Mikkelson, 2016 UT App 136 (June 30, 2016)

After observing a probationer step into the defendant’s car in violation of her 11:00 p.m. curfew, two police officers called the probation officer. The probation officer asked the officers to approach the probationer to “find out what’s going on,” which they did by pulling over the defendant. Incident to the officer’s investigation of the probationer’s probation violation, the officers discovered the defendant had drug paraphernalia on her person. The Utah Court of Appeals held (1) “police officers may investigate, search, and seize probationers under the direction of probation officers,” and (2) “a driver may be lawfully detained incident to a traffic stop initiated for the purpose of investigating a passenger’s parole or probation violation.”