Rodriguez v. United States

Once a traffic stop is completed, a dog sniff is unreasonable without additional reasonable suspicion.

Petitioner was pulled over for violating a state law that prohibits driving on highway shoulders. Once the police officer completed the ordinary traffic stop inquiry, he asked permission to walk his dog around the vehicle. When Petitioner did not grant permission, the officer asked Petitioner to exit the vehicle. The dog alerted to a bag of methamphetamines. The search resulted in a seven to eight minute extension of the completed traffic stop. In Illinois v. Caballes, the Court held that the Fourth Amendment was not violated by a dog sniff conducted during a traffic stop. This case distinguishes a dog sniff conducted after a traffic stop is complete. The Court held that an extension of time beyond the original purpose of the stop, absent reasonable suspicion, violates the Constitutional protection against unreasonable search and seizure. A stop remains reasonable for the length of time it takes to complete the task that justified the stop. Completing the stop expeditiously does not allow for additional inquires within the reasonable time. Prolonging the stop beyond the time necessary to complete the task renders the stop unreasonable.