Erickson Meko Campbell v. United States
FourthAmendment CriminalProcedure
Whether the exclusionary rule should apply when the only precedent the officer could rely on was not directly on point, explicitly rejected a bright-line rule pre-authorizing the seizure in favor of a totality of the circumstances analysis, and was out of step with this Court's prior and subsequent decisions governing the seizure
QUESTION PRESENTED This case stems from evidence obtained during a traffic investigation of a faulty turn signal and failure to maintain a lane. The officer delayed completing the traffic investigation in order to ask the Petitioner whether he had any counterfeit shoes, purses, shirts, pirated CD’s, pirated DVD’s, illegal alcohol, marijuana, cocaine, meth, heroin, ecstasy, or dead bodies in his car — questions not justified by reasonable suspicion, and that the officer admitted were irrelevant to the traffic investigation. The Eleventh Circuit found the prolongation of the traffic stop violated Rodriguez v. United States, 135 S.Ct. 1609 (2015), but it applied the good faith exception to the exclusionary rule, finding a reasonable officer could have relied on its decision in United States v. Griffin, 696 F.3d 1354 (11th Cir. 2012) to authorize the prolongation. The question presented is: whether the exclusionary rule should apply when the only precedent the officer could rely on was not directly on point, explicitly rejected a bright-line rule pre-authorizing the seizure in favor of a totality of the circumstances analysis, and was out of step with this Court’s prior and subsequent decisions governing the seizure. i