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acted reasonably under the totality of the circumstances presented to them.” United States v.
Hill, 852 F.3d 377, 381 (4th Cir. 2017) (quoting Rodriguez, 575 U.S. at 357).
“[T]he tolerable duration of police inquiries in the traffic-stop context is determined by
the seizure’s ‘mission’—to address the traffic violation that warranted the stop .” Rodriguez, 575
U.S. at 354 (citation omitted). A lawful detention does not end until the “tasks tied to the traffic
infraction are—or reasonably should have been—completed.” Id. “[A traffic] stop ends when
the police have no further need to control the scene, and inform the driver and passengers they
are free to leave.” Arizona v. Johnson, 555 U.S. 323, 333 (2009) (citation omitted). An officer
is not permitted to stray from the mission of the traffic stop by engaging in a detour to investigate
other crimes. Rodriguez, 575 U.S. at 356-57. For example, “a dog sniff [to detect illegal drugs]
is not fairly characterized as part of the officer’s traffic mission.” Id. at 356. Inquiries that relate
to the mission of the traffic stop include ordinary inquiries incident to the traffic stop and
inquiries designed to ensure “officer safety.” Id. at 355-56.
With respect to the first category, tasks that relate to the mission of the traffic stop,
officers may ask questions as they assess whether to issue a traffic ticket, and they may “check[]
the driver’s license, determin[e] whether there are outstanding warrants against the driver, and
inspect[] the automobile’s registration and proof of insurance.” Id. at 355.
In this connection, it is worth noting that “pure small talk, encompassing anodyne
conversation” that commonly occurs in the flow of a typical stop does not run afoul of the Fourth
Amendment. United States v. Ross, 151 F.4th 487, 496 (3rd Cir. 2025). Such small talk “carries
no constitutional significance and instead simply rides sidecar to the stop’s mission.” Id. An
officer’s “common greetings and courtesies,” such as “pleasantries about the weather . . . are Jump to an indexed page (10 of 10)