Traffic Stop Cannot Be Extended to Conduct Dog Sniff

The Supreme Court of the United States held in an April 21, 2015 decision that police cannot extend a traffic stop in order to conduct a dog sniff of the vehicle.

In Rodriguez v. United States, an individual was pulled over for veering onto the shoulder of a Nebraska State Highway. Following the stop, the officer obtained the driver's information and ran the standard records check. A warning ticket was written and handed to the driver along with his information. The driver was then detained for an additional period of seven to eight minutes until a drug dog arrived to conduct a dog sniff.

The Fourth Amendment of the United States Constitution protects everyone from unreasonable searches and seizures. In Illinois v. Caballes, a 2005 decision, the Court noted that a seizure justified only be a police-observed traffic violation becomes unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation. Rodriguez confirmed that a police stop exceeding the time needed to handle the matter for which the stop was made violates the Constitution's shield against unreasonable seizures.

The Court reasoned that when an individual is stopped for a traffic violation, the officer's mission includes checking the driver's license, determining whether there are outstanding warrants against the driver, inspecting the automobile registration and proof of insurance, and determining whether to issue a traffic ticket. By contrast, a dog sniff is a measure aimed at detecting evidence of ordinary criminal wrongdoing. A dog sniff is not an ordinary part of a traffic stop.