On April 21, 2015, the United States Supreme Court decided Rodriguez v. United States. The case involves a dog sniff conducted after the completion of a traffic stop.
In this case, a K-9 officer pulled Rodriguez over after watching his car veer slowly onto the highway shoulder, a violation of Nebraska law.
The officer gathered all necessary documentation, including Rodriguez’s license, registration and proof of insurance, at which time he went to his patrol car to run a records check. The officer then returned to Rodriguez’s car and began to question the passenger, while gathering the passenger’s credentials to run a records check. At this time, the officer also called for backup.
The officer returned to Rodriguez’s car a third time to issue a written warning for the traffic violation. He then took some time to explain the warning to Rodriguez, while also returning all credentials and documentation to Rodriguez and his passenger.
The officer then asked Rodriguez if he could walk his dog around the car. Rodriguez refused. The officer instructed Rodriguez to turn off the ignition and step out of the car. Rodriguez complied. When backup arrived, the officer walked his dog around Rodriguez’s car twice. The dog alerted that there were drugs in the car.
Rodriguez was indicted on one count of possession with intent to distribute 50 grams or more of methamphetamine, in violation of 21 U.S.C. §§841(a)(1) and (b)(1).
Rodriguez moved to suppress the evidence seized from the vehicle on the grounds that the officer prolonged the traffic stop without reasonable suspicion in order to conduct the dog sniff.
The Supreme Court held that a police stop exceeding the time reasonably required to handle the matter for which the stop was made becomes unlawful and violates the Constitution’s shield against unreasonable seizures.