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Supreme Court: Police Cannot Extend Traffic Stops

April 21, 2015 Criminal Law and Procedure

The United States Supreme Court ruled today that police may not prolong a traffic stop to wait for drug sniffing dogs to inspect vehicles.

Justice Ginsburg authored the 6-3 majority opinion.

Dennys Rodriguez was driving on a Nebraska highway when he swerved onto the shoulder of the highway and drew the attention of a police officer. The officer pulled Rodriguez over, ran a background check, and issued him a warning.

It was at this point in the interaction that Justice Ginsburg said the routine traffic stop was over.

The officer then asked Rodriguez for permission to allow a drug-sniffing dog to circle the car. Rodriguez told the officer no.

Rodriguez was ordered out of the car and made to wait for a second officer to arrive at the scene. The drug-sniffing dog then did two laps around Rodriguez’s car, alerting the officers of the possible presence of drugs, and resulting in a search of the car that revealed a bag of methamphetamine. About 8 minutes had passed between when the officer issued Rodriguez the warning and the detection of drugs by the dog.

Rodriguez made a motion to suppress the evidence, arguing that the police officer violated the Fourth Amendment of the Constitution when he prolonged the traffic stop without reasonable suspicion in order for the drug sniffing dog to conduct its search.

The district court denied the motion, finding that although the police officer had no reasonable suspicion to keep Rodriguez after the traffic stop concluded, the extended stop for the drug sniffing dog was only a minor intrusion on Rodriguez’s Fourth Amendment rights.

The Supreme Court took up the case to answer the question of whether police may routinely extend a completed traffic stop without reasonable suspicion so that a drug sniffing dog may conduct a search of a vehicle.

In general, the Court explained, the police may stop and pull over drivers and keep them for an amount of time that is limited by the reason for the stop in the first place. This means that once the reason for the stop of a driver has been addressed, police are supposed to discontinue the stop.

In the context of a traffic infraction, such as in this case, the stop is over once a ticket or warning has been issued. The extension of a routine traffic stop to enable a drug sniffing dog to search the car without reason goes beyond the reason for the stop.

“A police stop exceeding the time needed to handle the matter for which the stop was made violates the Constitution’s shield against unreasonable seizures,” wrote Justice Ginsburg.

The Supreme Court ultimately held that the police may not prolong a routine traffic stop so that a drug sniffing dog may inspect a vehicle.

The Supreme Court sent the case back to the district court for a redetermination based on its ruling.

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