This page uses extracted PDF text. Text can misread numbers, dates or table columns. Check the PDF before quoting or interpreting it. Redacted areas remain redacted.
7
driver and the passenger so that another officer could arrive with a dog who would sniff for
drugs. Id. at 352. An additional seven or eight minutes elapsed before the dog alerted to the
presence of drugs. Id. Charged with the possession of illegal drugs, Rodriguez filed a motion to
suppress, contending that once the mission of the traffic stop had ended, police were not free to
detain him further. Id. at 352. The Supreme Court agreed, holding that “a police stop exceeding
the time needed to handle the matter for which the stop was made violates the Constitution’s
shield against unreasonable seizures.” Id. at 350. Specifically, “[a] seizure justified only by a
police-observed traffic violation, therefore, becomes unlawful if it is prolonged beyond the time
reasonably required to complete the mission of issuing a ticket for the violation.” Id. at 350-51
(citation, brackets and quotation marks omitted).
The situation in this case differs from the one the officers confronted in Rodriguez. In
Rodriguez, the officer initiated a separate investigation unrelated to the traffic ticket and he did
so after the mission of the traffic stop had ended. Here, the mission of the traffic stop was not
complete, even though the officer informed Knight-Walker that he would not arrest her, because
Officer Allen had a “further need to control the scene.” Johnson, 555 U.S. at 333 (citation
omitted).
Knight-Walker could not lawfully drive her car due to her suspended license, and her
passenger likewise could not drive. She informed the officer that she would be calling her son so
that he could pick her up and drive her and the car away. As the circuit court observed, a
reasonable officer in these circumstances would not simply drive away from the scene, leaving
Knight-Walker with her car keys next to a car she could not lawfully drive. Instead, the officer
could sensibly wait for Knight-Walker’s son to arrive. The mission of the stop at that point was Jump to an indexed page (10 of 10)