Rodriguez v. United States
Case # 13-9972
Full Text of Opinion: http://www.supremecourt.gov/opinions/14pdf/13-9972_p8k0.pdf
Rodriguez was pulled over by a Police Officer one night after he veered onto a shoulder and jerked back onto the road. The Officer ran a records check on both Rodriguez and his passenger and questioned them about where they were coming from and going to. The Officer eventually went back to his patrol car where he completed his records check and called for a second officer. After finishing writing a written warning, the Officer returned to Rodriguez’s car and gave it to him. The Officer later testified that he had returned all the documents, finished explaining the warning to Rodriguez, and “got all the reason[s] for the stop out of the way.” Nevertheless, the Officer did not consider Rodriguez free to go. Although the justification for the traffic stop was “out of the way,” the Officer instructed Rodriguez to turn of the ignition, step out of the car, and stand in front of the patrol car to wait for the second officer to arrive. When the other Officer arrived, he led his police dog around Rodriguez’s car twice. The dog alerted to the presence of drugs on the second pass. All told, seven or eight minutes had passed from the time the Officer had concluded the traffic stop to the time the dog alerted to the drugs. A search revealed a large bag of methamphetamine.
Rodriguez was indicted in the United States District Court for the District of Nebraska for possession of methamphetamine. He moved to suppress the evidence seized from his car, arguing that the Officer had no reasonable suspicion that supported prolonging the stop after issuing the traffic warning. The Magistrate Judge concluded that the Officer lacked reasonable suspicion, but then concluded that extending the stop by “seven or eight minutes” for a dog sniff was on a de minimis intrusion on Rodriguez’s Fourth Amendments rights and was therefore permissible. Rodriguez’s motion to suppress was denied, and he ultimately entered a conditional guilty plea and was sentenced to five years in prison.
The Eighth Circuit affirmed, reasoning that the “seven or eight minute delay” was an acceptable de minimis intrusion on Rodriguez’s personal liberty. The United States Supreme Court granted certioriari to clear the matter on whether police routinely may extend an otherwise completed stop, without reasonable suspicion, in order to conduct a dog sniff.
The Supreme Court notes that the mission of a traffic stop is to enforce traffic codes. This mission consequently involves ordinary inquiries incident to the stop, such as checking driver’s licenses, determining whether there are outstanding warrants against the driver, and inspecting the automobile’s registration and proof of insurance. These checks ensure that vehicles on the road are operated safely and responsibly. In contrast, dog sniffs are aimed at “detecting evidence of ordinary criminal wrongdoing.” In other words, a dog sniff is not an ordinary incident of a traffic stop because a dog sniff has nothing to do with roadway safety. The Supreme Court points out that highway and officer safety are interests of a different kind from the Government’s endeavor to detect crime or drugs. Thus, the Supreme Court concludes that Rodriguez’s detention beyond completion of the traffic infraction for the dog sniff can be justified only if the Officer had reasonable suspicion of criminal activity. Accordingly, the case is remanded to the Eight Circuit for consideration on that issue.