United States v. Evans, No. 14-10024 (9th Cir. 2015)
Annotate this CaseThe United States appealed the district court's grant of defendant's motion to suppress evidence of illegal drugs and a firearm found in a search of his car after a traffic stop. Applying Rodriquez v. United States, the court held that the officer’s prolongation of the traffic stop to conduct both an ex-felon registration check and a “dog sniff” violated the Fourth Amendment unless the officer had independent reasonable suspicion to support the prolongations. The court vacated and remanded for the district court to address whether the officer had such reasonable suspicion.
Court Description: Criminal Law. The panel vacated the district court’s order granting James Evans’ motion to suppress evidence of illegal drugs and a firearm found in a search of his car following a traffic stop, and remanded. Applying Rodriguez v. United States, 135 S. Ct. 1609 (2015), the panel held that, by conducting an ex-felon registration check and a dog sniff, both of which were unrelated to the traffic violation for which he stopped Evans, an officer prolonged the traffic stop beyond the time reasonably required to complete his traffic mission, and so violated the Fourth Amendment, unless there was independent reasonable suspicion justifying each prolongation. The panel remanded to the district court for consideration in the first instance of whether the officer’s prolongation of the traffic stop was supported by independent reasonable suspicion.
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