Fourth Amendment/Unlawfully Prolonged Stop – The exclusionary rule does not apply if the officer diligently investigated, worked expeditiously, and reasonably relied on prior court rulings while conducting an otherwise valid traffic stop.
The Court reconsidered its prior holding in US v. Campbell from January 2019, where it held that suppression was warranted because the officer impermissibly prolonged the stop by asking questions unrelated to the stop.
This time around, the Court held that the exclusionary rule did not apply because the officer had “‘diligently investigated’ the traffic violations and ‘expeditiously’ completed the citations.” The Court further held that the officer “acted in ‘objectively reasonable reliance on binding appellate precedent.’”
Appeal from the Middle District of Georgia
Opinion by Tjoflat, joined by Martin and Murphy (by designation from E.D. Mich.)
Click here to read the opinion.