Code of Criminal Procedure · U.S. Supreme Court, 2015
Rodriguez v. United States
Rodriguez v. United States is a 2015 U.S. Supreme Court decision. This page summarizes key points and works through practice questions for Texas peace officer exam preparation.
Key points
- Stop limited to mission of addressing traffic infraction
- Ordinary incidents permitted (license/registration/warrant checks)
- Even a de minimis extension to conduct unrelated investigation requires independent reasonable suspicion
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Worked examples
Worked example 1
When officers extend the duration of a routine traffic stop solely to conduct a dog sniff (with no independent reasonable suspicion), the extension is:
- Always lawful
- Unlawful — Rodriguez v. United States holds that absent independent reasonable suspicion, even a de minimis extension of the stop to conduct an unrelated investigation violates the Fourth Amendment Correct
- Lawful for up to 30 minutes
- Lawful only if the dog is certified
Why: A traffic stop's duration is limited to addressing the traffic infraction and ordinary incidents (license, registration, warrant check). Any extension to conduct an unrelated investigation requires independent reasonable suspicion.
Statute: Rodriguez v. United States, 575 U.S. 348 (2015)