Rodriguez v. United States, 135 S.Ct. 1609 (April 21, 2015)
At first glance, this case didn’t strike me as all that important. Rodriguez, read narrowly, simply stands for the proposition that, when the Police detain a car and its passengers on the side of the road to wait for a K-9 to arrive and sniff around for drugs, the car’s occupants are seized. But after re-reading the case a couple of times, I’m now convinced that it’s actually much bigger than just another dog-sniff case.
The hallmark of much Fourth Amendment jurisprudence is the seemingly endless variety of methods Courts use to justify warrantless searches and seizures – and in the process, contribute to the further obfuscation of seemingly simple concepts. This unfortunate reality makes the clarity and simplicity of the Supreme Court’s discussion of Fourth Amendment law in Rodriguez all the more remarkable:
We hold 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. A seizure justified only by a police-observed traffic violation, therefore, “become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission” of issuing a ticket for the violation.
That’s actually clear, and easy to understand! When the Police detain a driver longer than necessary to issue a traffic citation or warning, the driver (and any passengers) is seized. In order for the seizure to be lawful, therefore, the Police will need to establish the requisite reasonable suspicion – based not on hunches and speculation, but on actual facts and evidence – that specific criminal activity is afoot.
In practice, this means that, when the Police want to take a simple traffic stop, and turn it into a criminal investigation for drugs or other contraband, they better have good reasons to do so. Otherwise, the Police conduct will be found unlawful, and its fruits suppressed.