Law School Case Brief
Rodriguez v. United States - 135 S. Ct. 1609 (2015)
The Fourth Amendment tolerates certain unrelated investigations that do not lengthen the roadside detention. However, judicial precedent cautions that a traffic stop can become unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a warning ticket. The seizure remains lawful only so long as unrelated inquiries do not measurably extend the duration of the stop. An officer, in other words, may conduct certain unrelated checks during an otherwise lawful traffic stop. But, he may not do so in a way that prolongs the stop, absent the reasonable suspicion ordinarily demanded to justify detaining an individual.
Officer Struble, a K-9 officer, stopped petitioner Dennys Rodriguez for driving on a highway shoulder, a violation of Nebraska law. After Struble attended to everything relating to the stop, including checking the driver's licenses of Rodriguez and his passenger and issuing a warning for the traffic offense, he asked Rodriguez for permission to walk his dog around the vehicle. When Rodriguez refused, Struble detained him until a second officer arrived. Struble then retrieved his dog, who alerted to the presence of drugs in the vehicle. The ensuing search revealed methamphetamine. Seven or eight minutes elapsed from the time Struble issued the written warning until the dog alerted. Rodriguez was indicted on federal drug charges. At trial in federal district court he moved to suppress the evidence seized from the vehicle on the ground, among others, that Struble had prolonged the traffic stop without reasonable suspicion in order to conduct the dog sniff. The magistrate judge recommended denial of the motion. He found no reasonable suspicion supporting detention once Struble issued the written warning. Under Eighth Circuit precedent, however, he concluded that prolonging the stop by "seven to eight minutes" for the dog sniff was only a de minimis intrusion on Rodriguez's Fourth Amendment rights and was for that reason permissible. The district court denied the motion to suppress. Rodriguez entered a conditional guilty plea and was sentenced to five years in prison. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. Noting that the seven or eight minute delay was an acceptable "de minimis intrusion on Rodriguez's personal liberty," the court declined to reach the question whether Struble had reasonable suspicion to continue Rodriguez's detention after issuing the written warning.
Did the appellate court properly rule that a seven or eight minute delay of a dog sniff was an acceptable de minimis intrusion on Rodriguez's personal liberty?
The Supreme Court of the United States held that absent reasonable suspicion, police extension of a traffic stop in order to conduct a dog sniff violated the Constitution's shield against unreasonable seizures. A police stop exceeding the time needed to handle the matter for which the stop was made violated the United States Constitution's shield against unreasonable seizures. It explained that a seizure justified only by a police-observed traffic violation became unlawful if it was prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation. In fact, a dog sniff was not fairly characterized as part of the officer's traffic mission since it lacked the same close connection to roadway safety as the ordinary inquiries. Lastly, the Court ruled that the question whether reasonable suspicion of criminal activity justified detaining defendant beyond completion of the traffic infraction investigation was open for consideration on remand as the lower court had not reviewed the determination that the detention for a dog sniff was not independently supported by individualized suspicion.
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