De La Rosa v. White, No. 15-3399 (8th Cir. 2017)
Annotate this CasePlaintiff filed suit against a state trooper under 42 U.S.C. 1983, alleging damages based on the trooper's unconstitutional initiation of a traffic stop and questioning, detainment, and arrest of plaintiff without reasonable suspicion or probable cause. After removal to federal court, the district court denied the trooper summary judgment based on qualified immunity. The court concluded, however, that the trooper was entitled to qualified immunity. In this case, the trooper pointed to objective, particular facts and explained why these facts led him to conclude he had reasonable suspicion to briefly extend defendant's detention to determine if a drug dog would alert to the exterior of a pickup truck traveling from Arizona to Illinois on Interstate 80. The court noted that more recent Eighth Circuit decisions have distinguished cases on which the district court primarily relied, and found no Fourth Amendment violations, let alone violations of clearly established Fourth Amendment law. The court explained that its prior cases have found reasonable suspicion upholding the extension of traffic stops by officers relying on similar facts. Accordingly, the court reversed and remanded.
Court Description: Loken, Author, with Riley and Beam, Circuit Judges] Civil case - Civil rights. The district court erred in denying the defendant State Trooper's motion for summary judgment based on qualified immunity on plaintiff's claim that the Trooper lacked reasonable suspicion to extend a traffic stop while he summoned a drug dog that alerted to plaintiff's truck; a reasonable officer could have believed he had a reasonable suspicion of criminal activity; recent Eighth Circuit cases have found reasonable suspicion upholding the extension of traffic stops relying on similar facts, such as difficulty in answering basic questions on itinerary and lies about criminal history; reversed and remanded with direction to enter summary judgment dismissing all claims against defendant.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.