State of Iowa v. Arrieta
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In this case from the Supreme Court of Iowa, the defendant, Stephen Arrieta, a truck driver, was pulled over at a weigh station after his vehicle failed a "PrePass" check. During the stop, an Iowa Department of Transportation officer requested a K-9 unit to conduct a free air sniff of the truck and trailer. The drug dog alerted to the presence of drugs in the sleeper compartment of the cab, and Arrieta admitted to having marijuana inside. Arrieta was subsequently charged with possession of a controlled substance.
Arrieta appealed the denial of his motion to suppress the marijuana. His main argument was that the officer unlawfully extended the time of his stop, known as a Level 3 inspection, to allow the K-9 handler to arrive and search his truck. Arrieta cited Rodriguez v. United States, a Supreme Court case that ruled such extensions of traffic stops without reasonable suspicion of criminal activity are unconstitutional.
The Supreme Court of Iowa agreed with Arrieta, finding that he was detained longer than necessary to complete the Level 3 inspection, in violation of the Fourth Amendment. The court concluded that the officer had effectively completed his tasks before the arrival of the K-9 unit and that the 25-minute delay until the K-9 unit's arrival was unjustified. As such, Arrieta was improperly detained when the free air sniff occurred, and any evidence obtained as a result of the search should have been suppressed.
The court vacated the decision of the Court of Appeals and reversed and remanded the judgment of the district court.
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