In a 6-3 decision in Rodriguez v. United States the Supreme Court held that a dog sniff conducted after a completed traffic stop violates the Fourth Amendment. Officer Struble pulled over Dennys Rodriguez after he veered onto the shoulder of the highway and jerked back on the road. Seven or eight minutes passed between Officer Struble issuing a warning, back up arriving, and Officer Struble’s drug-sniffing dog alerting for drugs. The Court concluded that exceeding the time needed to handle the matter for which the traffic stop was made violated the Fourth Amendment. Justice Ginsburg, writing for the majority, relied on Illinois v. Caballes where the Court upheld a suspicionless dog search conducted during (not after) a lawful traffic stop. In that case the Court stated that a seizure for a traffic stop “become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission” of issuing a ticket for the violation.
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