Rodriguez v. United States
United States Supreme Court
575 U.S. 348 (2015)
An officer stopped Rodriguez (defendant) after midnight for driving on the highway shoulder, collected the occupants' documents, ran background checks, called for backup, and issued written warnings. About seven or eight minutes after finishing the warnings and after backup arrived, the officer walked his drug-sniffing dog around the vehicle, over Rodriguez's objection; the dog alerted, and a search turned up drugs. The Eighth Circuit upheld the resulting conviction, reasoning the short delay for the dog sniff was a de minimis intrusion under circuit precedent. The Supreme Court granted certiorari.
Whether, under the Fourth Amendment, a police officer may prolong a routine traffic stop to have a drug-sniffing dog walk around the vehicle.