United States v. Rodriguez, No. 13-1176 (8th Cir. 2015)
Annotate this CaseDefendant pleaded guilty to one count of possessing with intent to distribute 50 grams or more of a mixture or substance containing a detectable amount of methamphetamine. On appeal, defendant challenged the district court's denial of his motion to suppress evidence. The court concluded that the traffic stop was not unreasonably prolonged by a dog sniff where seven or eight minutes had passed from the time the officer issued a written warning until the dog indicated the presence of drugs. Following remand from the Supreme Court, the Eighth Circuit again affirmed. When Rodriguez’s vehicle was stopped in March 2012, the law of the Circuit provided that a brief delay to employ a drug dog did not constitute an unconstitutional seizure, as long as the traffic stop was not unreasonably prolonged.
Court Description: Wollman, Author, with Colloton and Gruender, Circuit Judges] Criminal case - Criminal law. On remand from the Supreme Court. Rodriguez v. United States, 135 S.Ct. 1609 (2015). For this court's prior opinion in the matter, see United States v. Rodriguez, 741 F.3d 905 (8th Cir. 2014). The Supreme Court granted certiorari in this case to decide whether police routinely may extend an otherwise-completed traffic stop, absent reasonable suspicion, in order to conduct a dog sniff and held that a police stop exceeding the time needed to handle the matter for which the stop was made violated the Constitution's shield against unreasonable seizures; here, the officers acted in good faith reliance on existing Circuit precedent and the search, which was made in objectively reasonable reliance on binding circuit precedent, was not subject to the exclusionary rule; as a result, the evidence seized was admissible, and defendant's conviction is affirmed.
This opinion or order relates to an opinion or order originally issued on January 31, 2014.
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