Jacques S. Gholston v. United States
FourthAmendment CriminalProcedure Privacy
Whether a traffic stop unreasonably prolonged beyond the time needed to address the purpose of the stop violates the Fourth Amendment regardless of when, chronologically, the delay occurs?
QUESTION PRESENTED In Rodriguez v. United States, 575 U.S. 348, 350 (2015), this Court held that “a police stop exceeding the time needed to handle the matter for which the stop was made violates the Constitution's shield against unreasonable seizures.” Rodriguez v. United States, 575 U.S. 348, 350 (2015). When the police stop is based on a policeobserved traffic violation, the stop ‘become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission’ of issuing a ticket for the violation.” Id. at 350-51 (quoting Illinois v. Caballes, 543 U.S. 405, 407 (2005)). In this case, the court of appeals acknowledged the traffic stop was extended when the officer conducting the stop detoured from the mission of the stop into a methamphetamine investigation. Despite this finding, the court of appeals found no Rodriguez violation because the delay occurred before the officer finished writing the traffic citation. The question presented is: Whether a traffic stop unreasonably prolonged beyond the time needed to address the purpose of the stop violates the Fourth Amendment regardless of when, chronologically, the delay occurs?