This is a good case that re-emphasizes the holding in State v. Oryall, 2018 UT App 211 regarding an officer's ability to run license plate checks, and to act upon the information the officer receives.
In the present case, defendant was at a gas station and an officer was randomly running license plates on vehicles at the gas station. Officer observed that the vehicle was registered to "Donald Anderson" and upon further checks, realized Donald Anderson had active warrants for his arrest. Once defendant was done pumping gas he pulled up to a stall to go into the gas station. Officer pulled up either near or behind defendant (there was a dispute on which was correct at the evidentiary hearing), and approached the driver side door. Through an open window officer asked if he was "Donald Anderson," which defendant confirmed and immediately proffered to the officer that he had a warrant for his arrest.
Defendant argued that the search violated the consitution as he had no reasonable suspicion to do so, and that parking behind him was an illegal seizure as well. The Court of Appeals rejected both arguments. People do not have a reasonable expectation of privacy in their motor vehicle records, and therefore, this is not an illegal search under the Fourth Amendment. Also, it is a "commonsense inference" that the registered owner of the vehicle is the one driving it, and therefore, even assuming defendant was seized, it was a proper seizure.
There is some GRAMA discussion here in the case as well, but ultimately, this is a helpful case on running plates and officers being able to reasonably act on the information they obtain from running a plate.
You can find the full opinon here: State v. Anderson.
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