Rodriguez v. United States

[3] Some analysts have suggested that the Court's decision to limit police authority was influenced by ongoing protests in Ferguson, Missouri.

[17] Rodriguez filed a motion to suppress evidence discovered by the drug detection dog, arguing that an officer may not extend an already completed traffic stop to conduct a canine sniff without reasonable suspicion or other lawful justification.

[21] The Eighth Circuit held that a seven- to eight-minute detention was de minimis and reasonable to ensure officer safety.

[2] Consequently, a traffic stop becomes unlawful if "it is prolonged beyond the time reasonably required to complete the mission of issuing a ticket for the violation".

[25] Justice Ginsburg wrote that the purpose of the initial stop in this case was to investigate why Rodriguez swerved out of his lane of traffic.

[27] The Court then remanded the case to the Eighth Circuit to determine whether the officer did, in fact, have an independent basis for conducting the dog sniff.

[33] Additionally, Justice Alito claimed it was "arbitrary" for the court to hold the Fourth Amendment was violated "simply because of the sequence in which Officer Struble chose to perform his tasks".

Sometimes the Supreme Court corrects its own mistakes this way – not overruling, but just quietly and slowly walking away, over years and various decisions, from a rationale that increasingly seems mistaken.

[43] Another suggested that Chief Justice John Roberts may have been influenced by the shooting of Michael Brown and that he "learned the lessons of Ferguson and is trading in his logical abstractions for some much-needed legal realism".

Dennys Rodriguez was arrested on a highway near Waterloo, Nebraska (pictured).
In her majority opinion, Justice Ruth Bader Ginsburg (pictured) held that "a dog sniff is not fairly characterized as part of the officer’s traffic mission". [ 24 ]