## Facts

- A DEA agent in a coastal area associated with drug trafficking observed a Pontiac traveling in tandem with an overloaded pickup truck with a camper.
- After following the vehicles for roughly 20 minutes, the agent sought assistance and initiated an investigative stop of both vehicles.
- The Pontiac stopped, but the pickup continued and was stopped farther down the road by a state highway patrol officer.
- The DEA agent detained the Pontiac’s driver while attempting radio coordination and arranging for local police to supervise the Pontiac.
- The patrol officer detained the pickup’s driver and told him he would be held until the DEA agent arrived.
- About 15 minutes after the pickup was stopped, the DEA agent arrived, smelled marijuana from the camper, opened the rear without consent, saw burlap-wrapped bales, and arrested the pickup’s driver.
- The agent then returned and arrested the Pontiac’s driver; testing confirmed the bales contained marijuana.

## Issues

1. Whether the duration of the roadside investigative detentions transformed the stops into unreasonable seizures under the Fourth Amendment.
2. Whether the marijuana discovered in the pickup must be suppressed as the fruit of an unlawful seizure.

## Decision

- The Supreme Court reversed the appellate court and reinstated the convictions.
- The Court held the pickup driver’s detention satisfied the Fourth Amendment’s reasonableness requirement for a Terry-type investigative stop.
- The Court rejected a rigid, time-based rule for evaluating the constitutionality of investigative detentions.
- The Court held it need not decide whether the Pontiac driver’s detention was too long because the marijuana found in the pickup was not causally connected to that detention.

## Legal Principles

- Investigative detentions under Terry have no fixed maximum duration; the controlling inquiry is overall reasonableness under the circumstances.
- In assessing whether a detention is too long, courts should examine whether police diligently pursued investigative steps likely to confirm or dispel suspicion quickly.
- Duration is a factor, but courts should rely on common sense and ordinary human experience rather than rigid criteria.
- Suppression requires a causal connection between the alleged Fourth Amendment violation and the discovery of the challenged evidence.

## Conclusion

The Court held that an investigative vehicle stop is not unconstitutional solely because it lasts about 20 minutes; the Fourth Amendment inquiry turns on whether officers acted diligently and reasonably in a developing roadside investigation, and evidence is not excluded absent a causal link to any illegality.


United States v. Sharpe, 470 U.S. 675 (1985)