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Knight-Walker v. Commonwealth — 2025 opinion, later reversed

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- 19 - asks the driver if he likes the book, that question is clearly unrelated to the purpose of the traffic stop. And asking the question, and waiting for an answer, adds some measurable amount of time to the traffic stop beyond what a reasonable officer expeditiously completing the stop would have required. If the officer then sees a passenger in the backseat shift her foot to expose potential drug paraphernalia, giving her reasonable suspicion of drug activity, the evidence found from a resulting search would not need to be suppressed simply because unrelated questioning added some time to the stop. That is because the officer developed an independent basis to search the vehicle well within the time period during which “tasks tied to the traffic infraction . . . reasonably should have been” completed. Rodriguez, 575 U.S. at 355. Said another way, any incriminating evidence ultimately found would not be the product of the brief delay because, even without the questioning, the officer would have had cause to search within the time period authorized by the original stop. An analogous situation occurred in a case from the Idaho Supreme Court where a traffic stop included 28 seconds of questioning and delay that was unrelated to the mission of the stop. State v. Riley, 514 P.3d 982 (Idaho 2022). Even so, the evidence found after a drug dog alerted on the car did not need to be suppressed because the alert came 48 seconds before the tasks related to the traffic stop were completed. Id. at 989. In other words, had the extra questioning not taken place, the drug dog still would have alerted within the period of detention authorized by the original purpose and mission of the traffic stop. On the other hand, imagine that the same officer finished writing up a ticket for speeding, went back to the car with the ticket and license in hand, and only then engaged the driver over the novel in the front seat. Only after this exchange does the passenger in the backseat shift her foot to expose potential contraband. This would be a different case entirely. The factfinder would then have to scrutinize whether the traffic stop would have already ended before the foot
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