Sharpe accused the agent of violating the Fourth Amendment's prohibition of "unreasonable search and seizure", arguing that the stop was unduly prolonged prior to his arrest.
However, the Court declined to adopt a bright line rule, deciding instead that "common sense and ordinary human experience must govern over rigid criteria".
[1] The Court announced that the rule for determining whether a detention is too long will depend on whether the police "diligently pursued" an investigation to quickly confirm or dispel their suspicions.
The highway patrol officer continued pursuing Savage in the pickup truck while Agent Cooke approached Sharpe in the Pontiac.
Agent Cooke asked the Myrtle Beach PD to maintain the situation, then left to join the highway patrol officer who had successfully stopped the pickup truck one-half mile down the road.
[2] The Court noted at the onset that it need not decide whether Agent Cooke had reasonable articulable suspicion to initiate the traffic stop.
[1] The Court primarily discussed four cases as precedent for its decision: Terry v. Ohio,[3] Dunaway v. New York,[4] Florida v. Royer,[5] and United States v.
Terry was relevant here because the case requires that any police investigatory stop be "reasonably related in scope to the circumstances which justified the interference in the first place."
But the Supreme Court focused on language in the Place decision that stated the analysis was partly about "whether the police diligently pursue their investigation.
The Supreme Court stated it would not draw a "bright line" rule but instead would rely on "common sense and ordinary human experience" instead over "rigid criteria.
But the Supreme Court clarified that the question is not simply whether some alternative investigation decision was available, but instead "whether the police acted unreasonably in failing to recognize or to pursue it.
[1] The Supreme Court rejected the argument that a 20-minute stop is automatically unreasonable when the police were diligent and when a suspect's actions contribute to the added delay.
And the Court noted that the delay in the case was attributable "almost entirely to the evasive actions of Savage" when he sought to elude police, resulting in the one-half mile gap between the two vehicles.
Justice Marshall worried about "those who rank zealous law enforcement above all other values" abusing the Terry doctrine and using it to justify intrusive behavior.
[1] Justice Marshall proposed a test for Terry stops where the "critical threshold issue is the intrusiveness of the seizure" regardless of how efficient it may be for law enforcement based on the circumstances.
Justice Marshall wrote about the difficulty of judging the brevity requirement "by a stopwatch", but was uncomfortable with the Court's open-ended approach, believing that 20 minutes was too long.
Justice Marshall thought the majority was "so anxious to address an unpresented issue that it blithely hurdle[d] over the jurisdictional and jurisprudential principles that out to stand in its way".
Justice Marshall did not explicitly state whether he thought there was reasonable articulable suspicion, but he disagreed with the Court's decision to assume it without the issue being properly presented and briefed.
Justice Brennan pointed out that the government provided no explanation why the highway patrolman could not have investigated Savage without needing to wait for Agent Cooke.
Justice Stevens thought the Defendants' attempt to escape should have mooted the appeal, therefore making it unnecessary for the Supreme Court to even decide the constitutional question.
He suggests the entire analogy of routine traffic violations to Terry stops is unnecessarily confusing and the Court should instead adopt a new category of "non-custodial arrests."