Law School Case Brief
Illinois v. Caballes - 543 U.S. 405, 125 S. Ct. 834 (2005)
A seizure that is lawful at its inception can violate the Fourth Amendment if its manner of execution unreasonably infringes interests protected by the United States Constitution. A seizure that is justified solely by the interest in issuing a warning ticket to a driver can become unlawful if it is prolonged beyond the time reasonably required to complete that mission.
An Illinois state trooper stopped Roy Caballes for speeding on a highway. When the trooper radioed the police dispatcher to report the stop, a second trooper overheard the transmission. Although the second trooper presumably had no information about Caballes except that he had been stopped for speeding, the second trooper headed for the scene with a narcotics-detection dog. While the first trooper was writing a warning ticket, the second trooper walked the dog around the car, and the dog alerted at the trunk. On the basis of the alert, the troopers searched the trunk, found marijuana, and arrested Caballes. The entire incident lasted less than 10 minutes.
An Illinois trial court, in denying Caballes’ motion to suppress the seized evidence and quash the arrest, concluded that (1) the officers had not unnecessarily prolonged the stop, and (2) the dog alert was sufficiently reliable to provide probable cause to conduct the search. The Appellate Court of Illinois affirmed. However, the Supreme Court of Illinois, in reversing, said that because the canine sniff had been performed without any specific and articulable facts to suggest drug activity, the use of the dog had unjustifiably enlarged the scope of a routine traffic stop into a drug investigation.
Did the dog sniff that was performed on exterior of driver's car while driver was seized for a valid traffic violation violate Federal Constitution's Fourth Amendment?
The U.S. Supreme Court held that the use of a well-trained narcotics-detection dog -- one that did not expose noncontraband items that otherwise would have remained hidden from public view--during a lawful traffic stop -- generally did not implicate legitimate privacy interests. The dog sniff was performed on the exterior of respondent's car while he was lawfully seized for a traffic violation. Any intrusion on respondent's privacy expectations did not rise to the level of a constitutionally cognizable infringement.
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