Code of Criminal Procedure · Rodriguez v. United States

Rodriguez v. United States

Rodriguez v. United States is covered under Rodriguez v. United States and tested on the TCOLE peace officer licensing exam. Cadets typically encounter this topic under "Search & Seizure" on practice exams.

To prove this offense, the State must establish each of the following elements: 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.

Elements you must prove

  • 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

Practice 1 question on this topic

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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:

  1. Always lawful
  2. 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
  3. Lawful for up to 30 minutes
  4. 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)