The 2015 Supreme Court case of Rodriguez v. United States affects law enforcement officers in South Carolina and across the United States, from highway patrol to municipal officers. Though the case was decided a few years ago, its holding is still relevant and binding today.
In Rodriguez v. United States, the Court held that the dog sniff of a vehicle, which constitutes a “search,” that occurs without reasonable suspicion of wrongdoing is unconstitutional under the Fourth Amendment. The Court reasoned that it was unreasonable to keep a person “seized” or stopped for a traffic infraction for longer than necessary to complete the purpose of the stop.
Dennys Rodriguez was stopped by law enforcement for a minor traffic infraction. After receiving a warning from the officer, Rodriguez was asked whether the officer could walk a dog (not then present) around the vehicle and perform a dog sniff. Rodriguez declined. Nevertheless, when another deputy arrived with the dog, they performed the search by walking the dog around the vehicle. Methamphetamine was found and Rodriguez was ultimately found guilty and sentenced to prison.
Here’s the rub: Rodriguez never gave the officer permission to search his vehicle and the purpose of the stop had been completed before the dog-sniff-search commenced. In other words, it was unreasonable to keep Rodriguez detained for the time it took the second deputy to arrive because the “scope of the detention must be narrowly tailored to the underlying justification. Here, the “underlying justification” for the stop was a traffic stop not a reasonable suspicion of drug possession.
According to the Municipal Association of South Carolina, Rodriguez v. United States constitutes one of the seven cases of “significance…for local governments.” South Carolina police, along with those in other states, must have reasonable suspicion of wrongdoing in order to have authority to extend a vehicle stop longer than is necessary to complete the purpose of that stop.