Rodriguez v. United States
575 U.S. ____ (2015) (2015)
Rule of Law:
A police stop that exceeds the time reasonably required to complete the mission of issuing a traffic ticket violates the Fourth Amendment's prohibition against unreasonable seizures. Authority for the seizure ends when tasks tied to the traffic infraction are, or reasonably should have been, completed, unless new reasonable suspicion arises.
Facts:
- Just after midnight on March 27, 2012, Officer Morgan Struble observed a Mercury Mountaineer, driven by Dennys Rodriguez, veer onto the shoulder of a Nebraska highway.
- Struble initiated a traffic stop for the violation.
- Struble took Rodriguez's and his passenger Scott Pollman's information, ran records checks, and wrote a warning ticket.
- By 12:28 a.m., Struble had issued the written warning and returned all documents to Rodriguez and Pollman, completing all tasks related to the traffic stop.
- After the traffic-related tasks were complete, Struble asked for permission to conduct a canine sniff around the vehicle, which Rodriguez refused.
- Struble instructed Rodriguez to exit the vehicle and wait for a second officer to arrive.
- Approximately seven to eight minutes after the traffic stop's purpose was concluded, a second officer arrived, Struble conducted the canine sniff, and the dog alerted to the presence of drugs.
- A subsequent search of the vehicle revealed a large bag of methamphetamine.
Procedural Posture:
- Dennys Rodriguez was indicted in the U.S. District Court for the District of Nebraska on a federal drug charge.
- Rodriguez filed a motion to suppress the evidence, which a Magistrate Judge recommended denying, finding the seven-to-eight minute delay for the dog sniff was a permissible 'de minimis' intrusion.
- The District Court adopted the magistrate's recommendation and denied the motion to suppress.
- Rodriguez entered a conditional guilty plea and appealed the denial of his suppression motion to the U.S. Court of Appeals for the Eighth Circuit.
- The Eighth Circuit, with Rodriguez as appellant and the United States as appellee, affirmed the trial court's decision, holding the delay was a constitutionally acceptable 'de minimis intrusion'.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Does a police officer violate the Fourth Amendment's prohibition on unreasonable seizures by prolonging an already-completed traffic stop for a canine sniff, absent reasonable suspicion?
Opinions:
Majority - Justice Ginsburg
Yes. A police stop prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation becomes an unlawful seizure. The Fourth Amendment's tolerance for a traffic stop is determined by the seizure's 'mission'—to address the traffic violation and attend to related safety concerns. Ordinary inquiries incident to the stop, like checking a driver's license and registration, are permissible as they serve the mission of ensuring roadway safety. However, a canine sniff is an investigative measure to detect evidence of ordinary criminal wrongdoing and is not part of the traffic mission. Therefore, any extension of the stop to conduct such a sniff, after the traffic mission is or reasonably should be completed, is unconstitutional absent independent reasonable suspicion.
Dissenting - Justice Thomas
No. The seizure was not unreasonable and therefore did not violate the Fourth Amendment. The ultimate touchstone of the Fourth Amendment is reasonableness, and the total duration of the stop (29 minutes) was not out of the ordinary. The majority's rule creates an arbitrary 'mission' test that depends on an officer's efficiency and incorrectly limits the scope of a stop based on probable cause by applying principles from reasonable-suspicion cases. Furthermore, this ruling was unnecessary because the officer possessed reasonable suspicion to prolong the detention based on the overwhelming smell of air freshener, the passenger's nervousness, and the driver's implausible travel story.
Dissenting - Justice Alito
No. The Court's decision is unnecessary, impractical, and arbitrary because the officer already had reasonable suspicion to detain Rodriguez, making the Court's ruling on a hypothetical scenario purely academic. The majority's holding creates a perverse rule based on the sequence of an officer's actions rather than the overall reasonableness of the stop's duration. It punishes an officer for taking the reasonable safety precaution of waiting for backup before conducting the sniff, an action that would have been deemed lawful had it been performed in a different, more dangerous sequence.
Analysis:
This decision clarifies the Court's holding in Illinois v. Caballes by establishing a bright-line rule regarding the duration of traffic stops. It firmly rejects a 'de minimis' exception that would allow for slight prolongations for unrelated investigations. The ruling effectively ends the practice of officers using routine traffic stops as a pretext to conduct fishing expeditions for other crimes after the stop's initial purpose has been served. In practice, this requires law enforcement to develop independent reasonable suspicion for any continued detention before or at the moment the traffic-related tasks of the stop are completed.
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