MRR News Alert – U.S. Supreme Court: Traffic Stops Cannot Be Overly Prolonged Or Go Beyond Their Mission

The U.S. Supreme Court held that absent reasonable suspicion, the extension of a police traffic stop to conduct a dog-sniff violates the constitutional prohibition against unreasonable seizures. Reversing the Eighth Circuit Court of Appeals, the Supreme Court held that a traffic stop becomes unlawful when it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket.

In Rodriguez v. The United States, No. 13-9972, a canine officer stopped a motorist (Rodriguez) for driving on a highway shoulder in violation of Nebraska state law. After the officer completed everything related to the stop, the officer requested the motorist’s permission to walk his K-9 around the vehicle. The motorist refused and the officer detained him for seven or eight additional minutes while his dog searched for drugs. The dog found drugs. After being indicted on federal drug charges, the motorist moved to suppress the drugs seized from the vehicle because the officer had prolonged the traffic stop without reasonable suspicion. The Eighth Circuit Court of Appeals found that prolonging the stop for the dog sniff was only a de minimus (or minimal) intrusion into the motorist’s Fourth Amendment rights and was therefore permissible.

In a 6-3 decision, the Supreme Court reversed, finding that the extension of the traffic stop violated the Constitution because it was unreasonable. The Court explained that the authority for the seizure ended when the tasks tied to the traffic infraction are, or reasonably should have been, completed. If the roadside detention extends beyond the time reasonably required to complete the mission of issuing the ticket, the traffic stop becomes unlawful. The Court found that the mission of issuing a traffic ticket included checking the driver’s license, investigating the existence of outstanding warrants, and reviewing the motorist’s proof of insurance and registration documents. These checks go to the same objective as enforcing the traffic code: ensuring that vehicles on the road are operated responsibly and safely. The Court explained that a dog-sniff is not fairly characterized as part of the officer’s traffic mission. The Court found that on-scene investigation into other crimes is a departure from the officer’s traffic control mission.

Ultimately, the issue of whether the motorist’s detention will be found lawful was not completely resolved either. The Supreme Court found that the Eighth District did not review whether the district court properly determined the dog-sniff was not independently supported by individualized suspicion. The Court found that that question remains open for consideration of further action.

The Supreme Court made clear that traffic stops have to be reasonably short unless there is an independent, reasonable suspicion of another crime that allows further investigation and prolonging the traffic stop. Officers simply cannot prolong a traffic stop just to perform a dog-sniff drug search without otherwise having independent reasonable suspicion.

For more information on this subject matter or other appellate topics, please contact John T. McLandrich and Frank H. Scialdone.