CAN WE KEEP EVIDENCE OUT OF COURT THAT WAS DISCOVERED AFTER A PROLONGED DETENTION?
Sometimes the black letter law passed by the legislature is unclear. The legislature can’t anticipate every possible fact scenario when they pass a law, so it lay to the courts to interpret the law and give guidance to what it means. This interpretation is called case law. When the court decides a certain meeting to the law it essentially answers a legal question. Lawyers and other courts then can rely on that ruling when they have a similar issue in their case. The following case answers the question above.
Rodriguez v. United States, 135 S. Ct. 1609 (2015).
This case answers the following question:
Can evidence be used in court that was discovered after a prolonged detention?
The issue in this case is whether it is a Fourth Amendment violation for a police officer to conduct a dog sniff after the completion of a traffic stop. A seizure justified only by a police-observed traffic violation, therefore, becomes unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation.
In this case, a police officer pulled over a vehicle just after midnight after seeing the vehicle veer onto the shoulder for a few seconds before jerking back onto the highway. Since it is illegal to drive on highway shoulders in Nebraska, where the incident took place, it was acceptable for the officer to pull over the vehicle. The officer obtained Rodriguez’s license, registration, and proof of insurance since Rodriguez had been driving. After completing a records check on Rodriguez, the officer returned to the vehicle to obtain the passenger’s license and run a records check on him as well. Then the officer returned to the vehicle to issue Rodriguez a written warning. At this point, the justification for the traffic stop was complete, but the officer did not let the men leave. The officer asked Rodriguez to exit the vehicle and wait for a second officer. Once the second officer arrived, the first officer took his drug sniffing dog and walked him around the vehicle twice. On the second walk around, the dog alerted the officer to the presence of drugs in the vehicle, and upon search of the vehicle, the officer found a large bag of methamphetamine. Rodriguez was charged with possession with the intent to distribute, and the district court sentenced him to five years in prison.
A seizure justified only by a police-observed traffic violation, therefore, becomes unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation. Typically, during a traffic stop, a police officer is given the discretion to conduct other unrelated checks, so long as they do not prolong the stop. However, if the police officer has reasonable suspicion, a prolonged stop may be excusable.
In this case, the government argued that an officer could prolong a stop to conduct a dog sniff so long as the officer is reasonably diligent in pursuing the traffic-related purpose of the stop. The government argued that this was reasonable as long as the duration of the stop was reasonable. However, the court in this case reasoned that the prolonged stop for the dog sniff was not supported by any reasonable suspicion.
The Supreme Court reversed and remanded the decision of the lower courts. The Supreme Court remanded for the purpose of having the lower courts examine the issue of whether reasonable suspicion of criminal activity justified detaining Rodriguez beyond completion of the traffic violation investigation. If the lower court finds that this suspicion was not justification to detain Rodriguez beyond completion of the traffic stop, then the evidence that was discovered in this case would not be allowed in court.