## Facts

- A Nebraska police officer stopped Dennys Rodriguez’s vehicle after observing it briefly drive onto the highway shoulder, a traffic violation under state law.
- The officer collected identification and vehicle documents, questioned the driver and passenger, ran records checks, and prepared a warning for the traffic infraction.
- After completing the warning, the officer sought consent to conduct a canine sniff; Rodriguez refused.
- The officer detained Rodriguez until another officer arrived and then conducted a dog sniff seven to eight minutes after the warning was issued.
- The dog alerted, the vehicle was searched, and methamphetamine was discovered.
- Rodriguez was charged federally and moved to suppress, arguing the traffic stop was prolonged without reasonable suspicion; the district court denied the motion and the court of appeals affirmed on a “de minimis” extension rationale.

## Issues

1. Whether, absent reasonable suspicion, police may extend an otherwise completed traffic stop to conduct a dog sniff consistent with the Fourth Amendment.
2. Whether a brief (“de minimis”) prolongation of a traffic stop for an unrelated investigation is permissible without additional justification.

## Decision

- The Supreme Court held that, absent reasonable suspicion, extending a traffic stop to conduct a dog sniff is an unreasonable seizure.
- The Court rejected the view that a short extension can be justified as a “de minimis” intrusion.
- The Court vacated the judgment and remanded for consideration of whether reasonable suspicion supported the extension.

## Legal Principles

- A traffic stop’s permissible duration is limited to the time reasonably required to complete its mission: addressing the traffic violation and attending to related roadway-safety tasks.
- Ordinary incident-to-stop checks (e.g., driver’s license, warrants, registration, insurance) are part of the stop’s mission because they relate to safe and responsible vehicle operation.
- A dog sniff aimed at detecting evidence of ordinary criminal wrongdoing is not part of the traffic-safety mission.
- The controlling question is whether the sniff adds time to the stop; once traffic tasks are (or reasonably should have been) completed, continued detention requires independent reasonable suspicion.
- The Fourth Amendment does not allow “bonus time” or any prolongation—however brief—for unrelated investigative measures without reasonable suspicion.

## Conclusion

The Court ruled that police may not prolong a traffic stop beyond the time needed to complete traffic-related tasks in order to conduct a dog sniff unless the added detention is supported by reasonable suspicion of criminal activity.


Rodriguez v. United States, 135 S. Ct. 1609 (2015)