Dennys Rodriguez v the United States 575 U.S. ___ (2015)
The United States Supreme Court
The Supreme Court of the United States
The Judge Writing the Decision
Justice Ruth Bader Ginsburg
Facts of the Case/Brief Summary
The main issue for the court’s determination here was the constitutionality of an extended traffic stop, search, and seizure using a law enforcement officer’s detection dog to cover areas not initially covered by the reasonable suspicion of an offence having been committed. The brief facts are that the appellant was driving in violation of the laws of Nebraska State. Officer Struble stopped him and checked his license and then issued him a ticket warning for a traffic offense. The officer then asked for Rodriguez’s permission to have the vehicle searched by a sniff dog, but he refused. After calling for backup, the dog was walked around the vehicle and alerted the officers to the smell of drugs and on searching the car, methamphetamine, an illegal controlled substance, was discovered. Rodriguez was subsequently charged with a drug offense. He, however, filed a motion challenging the evidence of drugs obtained through the search. His primary argument against the use of the evidence against him was that the first officer had unnecessarily prolonged the traffic stop, and hence no reasonable suspicion justified existed. The Magistrate trial judge failed to grant the motion and after entering a conditional guilty plea, the appellant was sentenced to serve five years. The appellant appealed to the United States Court of Appeals for the Eighth Circuit to decide on the issue of whether no reasonable suspicion independently justified the officer to extend the stop. The appellate court agreed with the decision of the District Court. The court argued that the detention of Rodriguez for eight minutes is a de minimis intrusion of his privacy rights in the Fourth Amendme and reasonable for the safety of the officer. Aggrieved by this decision, Dennys appealed to the US Federal Supreme Court.
Holding/Ruling and Reasoning of Court
The highest court ruled that the officer’s action of exceeding the time necessary for handling the road issue was meant to be solved by the stop was a violation of the appellant’s Constitutional Fourth Amendment right and protection against unreasonable search and seizure. According to the court, the stop became unlawful and irrational at the point when it exceeded the period that was reasonably necessary for the completion of its mission which was to issue ticket for traffic violation through swerving traffic lanes. The legal authority of Oficer Struble of going on with the stop came to an end the moment when he completed investigating the traffic infraction. There was no relation at all, the court argued, between the initial violation’s investigation and the subsequent dog sniff that led to the discovery of the illegal drug in the vehicle.
Disposition
The Supreme Court and the Court of Appeals on the issue of suppression of the evidence collected through the search. However, it ordered that the case be remanded to the United States Court of Appeals for the Eighth Circuit for the determination of whether there was any independent basis upon which the officer did conduct the search.
Concurring and Dissenting Opinions
Justices Sonia Sotomayor, Ellen Kagan, Antonin Scalia, Stephen Breyer and John Roberts agreed with Ginsburg’s decision, affirming her reasoning and opinion on the issue. Their reasoning, as evident in the opinion of Justice Ginsburg was that a search using a specially trained dog is not part of a traffic police officer’s duties hence is a violation of a road user’s Constitutional rights of protection against unwarranted search or seizure.
Justices Clarence Thomas, Samuel Alito and Anthony Kennedy disagreed with the majority judgment and wrote independent dissenting opinions. According to Justice Thomas, the officer’s act of extending the search that yielded the drugs was reasonable. He argues that search using a police dog cannot make an otherwise legal stop by traffic officer or search unreasonable unless it is conducted in an unreasonable fashion. He based his reasoning on the Supreme Court’s ruling in Illinois v. Caballes, 543 U. S. 405, 408 (2005) Furthermore, his argument was that given that the appellant had not disputed the fact that the officer had probable cause in stopping him; the central question that was supposed to be determined by the court was whether the stoppage of driver by a traffic police officer had been conducted reasonably. Hence, according to him, the reasonable belief by the law enforcement officer that the appellant had committed an offence was in itself an independent justification for carrying out the search using the police dog. Justice Alito, on the other hand, tore into the majority decision, scathingly attacking it as being impractical, arbitrary and unnecessary. According to him, since the circumstances of the case met the court’s definition of ordinary standards for probable cause or reasonable belief, the search that led to the discovery of the drugs was justified. Moreover, his argument was that Justice Ginsburg’s decision was insensitive of officer safety since the first officer could have been attacked by the passenger and the driver had he carried out the search without backup. Finally, Justice Kennedy gave a rather short dissenting opinion in which he agreed with his dissenting colleagues but differed slightly on the question of the existence of reasonable suspicion. According to him, since the Eighth Circuit Court of Appeals had failed to the address the issue of reasonable doubt, it would be better if the court had sent the case to the lower court for further consideration.
Public Policy and Psychology Implications
The primary impact of this court’s decision on the criminal justice system is that it would extend the rights of accused persons in the Fourth Amendment and subsequently restrict the ability of traffic officers to conduct a legal search. It would also exposure traffic police officers to the danger of being attacked by suspects as this decision means they have to act at the spur of the moment and not wait, say, for backup. This would hinder their ability to combat criminal activities such as drug trafficking. The immediate impact on the society is that it would endanger the safety and security of members of the public when officers cannot detect crime for fear of infringing Fourth Amendment rights. Further, this decision would jeopardize the desire by the society to maintain safety on our roads. According to Arnold, what may have informed the decision of the court in this case could have been the need to respond to the “nation’s growing unease with incidents of routine traffic stops ending in violence” (136).
Personal Opinion
In my considered view, the opinion of the majority in this case was wrong and went too far in its interpretation of the Fourth Amendment rights. The justices paid lip service or consideration to the issue of safety of traffic cops and compelling state interest in maintaining safety on our roads and taming crime. There was clearly the existence of a reasonable belief that justified the dog sniff and hence the fact that Officer Struble waited for 7-8 minutes for backup to arrive before conducting the search is immaterial. I would, therefore, dissent had I been one of the Justices and decide that the exigencies of the situation in which the law enforcement officer found himself justified the use of the police dog to carry out the search.
Work(s) Cited
Arnold, Adrienne. "Rodriguez, Terry and the Supreme Court's evolving Fourth Amendment jurisprudence: How Rodriguez does (and does not) clarify the future of the Fourth Amendment." HLRe: Off the Record 6.1 (2015): 135-152. Web. 15 July 2016. < www.houstonlawreview.org/wp-content/uploads//Arnold_Final.pdf >
Dennys Rodriguez v the United States 575 U.S (2015). Web. 15 July 2016. < http://www.supremecourt.gov/opinions/14pdf/13-9972_p8k0.pdf.>.
