Fourth Amendment – Reasonable suspicion justified prolonging a traffic stop where the defendants’ answers to the officer’s routine questioning were implausible or contradictory.
The defendant appealed the district court’s order denying his motion to suppress. The defendant and two passengers were initially detained during a traffic stop based on the officer’s suspicion that they had an improperly displayed license plate. While approaching the vehicle, the officer noticed that the car was actually using a temporary tag. After checking the driver’s license, the officer asked the driver to exit the vehicle and look at his plate, during which he asked the defendant questions about his trip. The officer ran a background check on the names of the passengers and asked them about their trip.
When the background check for one passenger reflected an outstanding warrant, the officers arrested the passenger and requested to search the vehicle. The defendant stated that he did not want officers to search the vehicle given that he did not know what passengers might have put in it. The officer requested a more detailed background check which lasted six minutes. At that point, the other passenger stated that he had four prior drug arrests. The officer then deployed a K-9 , and the dog altered positive for narcotics in the vehicle. The car was then searched and evidence of fraud was found.
On appeal, the Court considered whether the officers had unlawfully prolonged the stop. First, the Court held that the officers were justified in continuing the stop even after confirming that the driver’s license was valid and that the vehicle was properly using a temporary license. The Court explained that a traffic stop may be extended to examine the licenses of a vehicle’s occupants, check for outstanding warrants, and even to ask the drivers and passengers questions about their destinations and purpose.
Second, the Court held that the officers had reasonable suspicion to prolong the stop beyond the investigation of the improperly displayed tag. The Court held that the defendants’ implausible answers and contradictory statements created that suspicion. For example, the defendants had failed to explain why they needed three men to pick up a small icemaker, why they were driving to another state to pick it up rather than have it shipped, and their stories for knowing each other and driving together were contradictory. Those circumstances, in addition to the officer’s training and experience that dishonesty among drivers “usually indicates that they are hiding contraband,” was sufficient to prolong the stop.
Appeal from the Southern District of Texas
Opinion by Dennis, joined by Graves and Willett
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