Rodriguez v. United States

Whether conducting a canine sniff without reasonable suspicion at the conclusion of a lawful traffic stop is a "de minimis" intrusion on personal liberty and is thus lawful under the Fourth Amendment.

An officer observed a vehicle swerve onto the shoulder of a highway and back onto the road, and initiated a traffic stop. After the officer checked the identification of the driver (Petitioner) and his passenger, the officer issued a written warning. The officer then asked Petitioner whether his K9 canine could walk around the vehicle. Petitioner refused, and the officer ordered him out of the vehicle. While conducting the canine sniff, the dog detected drugs during the second pass, and methamphetamine was found. Petitioner filed a motion to suppress the evidence because the traffic stop had concluded.

The district court denied Petitioner's motion to suppress. Petitioner appealed and the Court of Appeals for the Eighth Circuit upheld the decision stating that the stop was a de minimis intrusion on the Petitioner's liberty. The Supreme Court granted certiorari to determine whether reasonable suspicion is required for a canine sniff after a traffic stop has concluded.