Rodriguez v. United States

Our conservative United States Supreme Court recently handed down a decision, known as Rodriguez v. United States, that effectively limits law enforcement’s ability to extend a traffic stop beyond the time that is reasonably necessary to address the original reason for the stop, which is typically a minor traffic violation.

A traffic stop is considered to be a seizure under the 4th Amendment. However, because it is less intrusive than a formal arrest a different standard applies. For an arrest, an officer must have probable cause to believe that the arrestee has committed a crime. However, for a traffic stop an officer need only have a reasonable suspicion that the person stopped has broken a law. In most cases the law would be a minor traffic violation. The Supreme Court has long held that a traffic stop may only last as long as is reasonably necessary to deal with the situation that gave rise to it. However, many courts across the country interpreted its prior cases to mean that once an officer made a stop, he could investigate other matters so long as the stop was not unreasonably extended. As a result, officers who stopped a person for a minor traffic violation were often allowed to extend the stop and investigate other matters unrelated to it without running afoul of the 4th Amendment’s protections, despite the fact that they had no evidence that any other crime had been committed. Thankfully, those days are now at an end.

In Rodriguez, the police officer stopped the defendant for a traffic violation. After obtaining the defendant’s license, registration and insurance, the officer completed the paperwork related to the original reason for the stop. He then forced the defendant to stay at the scene for an additional 7-8 minutes so that a K9 unit could arrive. After the K9 unit arrived, the dog was walked around the vehicle and alerted to the presence of drugs inside. A search was conducted and drugs were located, which resulted in the defendant being charged with felony offenses. The defendant then challenged the constitutionality of the officer’s actions, and the case eventually made its way up to the United States Supreme Court.

In analyzing the matter the Supreme Court held that any extension of a traffic stop beyond the time needed to address the original reason for it is unreasonable and therefore a violation of the 4th Amendment. This means that if you are stopped, the officer may not force you to stay on scene while he investigates other possible crimes, unless he has evidence giving rise to a reasonable suspicion to believe that you have committed those other crimes. Under the holding of Rodriguez, it doesn’t matter if the stop is extended for one minute or one hour, once the original reason for the stop has been addressed the officer must let you go on your way. If he holds you longer than is reasonably necessary to address the original reason for the stop, he is likely violating the 4th Amendment, which means that any evidence obtained as a result of the stop’s extension will likely be inadmissible in any future prosecution.

Who says the constitution is dead?