Decided: December 14, 2015
The Fourth Circuit concluded the district court was incorrect in finding that reasonable suspicion existed to extend a traffic stop beyond its initial purpose; and therefore, vacated the defendant’s conviction and sentence and remanded for such other and further proceedings as may be appropriate.
Williams and his girlfriend were pulled over in North Carolina for speeding by a deputy sheriff. The deputy sheriff requested another deputy to stop and assist with administering a breathalyzer test after smelling alcohol. The test revealed that Williams was not intoxicated, and he was issued a written warning. Next, the officers asked if there was anything illegal in the vehicle, and Williams denied consent to search the vehicle. The officer told Williams to hold on, and the officer had a drug dog sniff the vehicle. The dog alerted the deputy, and a search of the trunk revealed crack cocaine. Williams attempted to suppress this evidence; however, he was unsuccessful. The court explained the Government had reasonable suspicion due to five specific factors: (1) Williams was driving in a rental car; (2) Williams was traveling in a known drug corridor; (3) Williams stated inconsistent travel plans; (4) Williams had contradictions in the addresses he provided; and (5) Williams stated he was traveling with the car ahead of him, but that car’s driver denied any association with Williams. Further, the court stated that the two-minute-and-forty-second extension for the dog sniff fell within the general parameters of a de minimis delay that does not offend the Fourth Amendment. However, after a reconsideration hearing, the evidence regarding the court’s fifth factor was determined to be inconsistent, but there was sufficient evidence to deny the suppression motions. Williams was sentenced to prison and this appeal followed.
On appeal, Williams reiterated his contention that the deputies did not have the reasonable suspicion required to extend the traffic stop beyond its initial purpose. The government conceded that the de minimis ground for denying the suppression was not legally valid. Since a traffic stop is a “seizure” and is akin to an investigative detention, the Fourth Circuit analyzed the constitutionality of such a stop under the two-prong test illustrated in Terry v. Ohio. First, the officer’s reason for the traffic stop needs to be reasonable. Second, the officer’s actions during the seizure needs to be “reasonably related in scope” to the basis for the traffic stop. In Rodriguez v. United States, the Supreme Court held that, absent reasonable suspicion of criminal activity, a detaining officer may not extend an otherwise-completed traffic stop in order to conduct a dog sniff. Under the second prong, authority for the seizure ends when tasks tried to the traffic stop are reasonably completed.
With respect to the first Terry prong, whether the reason for the traffic stop was legitimate, Williams did not dispute that the deputy had every right to stop his vehicle for speeding. However, the Fourth Circuit discussed Terry’s second prong, whether the officers’ actions were reasonably related in scope to the basis for the traffic stop. The propriety of extending Williams’ detention beyond the completion of the traffic stop turns on whether reasonable, articulate suspicion existed when the deputy decided to conduct a dog sniff of the vehicle. Reasonable suspicion is a commonsense, nontechnical standard that relies on the judgment of experienced law enforcement officers. The court was required to look at the totality of the circumstances.
The Fourth Circuit walked through each of the four factors used by the district court in determining that reasonable suspicion existed. The Fourth Circuit was critical of the use of the first factor, determining the reasons provided by the deputies that the fact that the defendant was driving in a rental car was of minimal value to the reasonable suspicion analysis. Similarly, the fact that the defendant was driving “on a known drug corridor at 12:37 a.m.” was not very convincing because the number of persons using the interstate highways as drug corridors pales in comparison to the number of innocent travelers on those roads, even at the late hour. Further, no reasonable, articulable suspicion of criminality arises from the mere fact that Williams’ travel plans were likely to exceed the initial duration of the rental agreement. Finally, although the district court related that Williams had failed to provide either deputy with his home address, the record showed that neither deputy specifically asked Williams for his home address. Neither officer identified any aspect of the fourth factor as suspicious. Each of the factors, standing alone, failed to support any reasonable, articulable suspicion of criminal activity.
Also, the Fourth Circuit noted “reasonable suspicion may exist even if each fact standing alone is susceptible to an innocent explanation.” However, the record failed to show how the four factors reasonably pointed to criminal activity. Therefore, the Fourth Circuit vacated Williams’ conviction and sentence and remanded for such other and further proceedings that may be appropriate.
Austin T. Reed