575 U.S. 348 (2015)
Rodriguez v. United States is a cornerstone Fourth Amendment case that sharply defines the permissible scope and duration of a traffic stop.
May an officer prolong an otherwise-completed traffic stop, even briefly, to conduct a dog sniff for narcotics absent independent reasonable suspicion of criminal activity beyond the traffic violation?
A seizure justified only by a traffic violation becomes unlawful if it is prolonged beyond the time reasonably required to complete the stop's mission, which includes addressing the traffic infraction and attending to related safety concerns (such as checking license, registration, insurance, and warrants). Tasks aimed at detecting evidence of ordinary criminal wrongdoing, including a dog sniff, are not part of that mission. Any extension of the stop for such purposes requires independent reasonable suspicion.
No. Absent independent reasonable suspicion, police may not extend a completed traffic stop to conduct a dog sniff. The seven- to eight-minute delay to conduct the sniff violated the Fourth Amendment. The judgment was reversed and the case remanded.
Rodriguez provides a clear, administrable rule for traffic-stop duration: once the traffic mission reasonably should be done, the seizure must end unless new reasonable suspicion arises. It forecloses the de minimis-delay rationale and thus significantly affects police training and roadside practices. For litigators, it offers a robust framework for suppression arguments centered on timestamps, body-camera footage, and the sequencing of tasks. Doctrinally, it aligns Terry-stop reasonableness with a mission-focused temporal limit and delineates the difference between safety-related checks and general crime-control measures.