Ever been pulled over and felt like the officer was just... hanging out? You've handed over your license. They’ve run your plates. The warning or ticket is sitting right there on the clipboard. But instead of letting you go, they keep you waiting on the shoulder of the highway for "just a few more minutes."
In the legal world, those minutes are a massive deal.
Honestly, the case of Rodriguez v. United States is probably one of the most practical Supreme Court rulings for the average person to understand. It’s not about high-level corporate tax law or some obscure property dispute. It’s about your time and your rights when you’re sitting in the driver’s seat with blue lights in the rearview.
What actually happened to Dennys Rodriguez?
It was just after midnight in March 2012. An officer named Morgan Struble saw a Mercury Mountaineer veer onto the shoulder of a Nebraska highway and then jerk back onto the road. Pretty standard stuff. He pulled the driver over.
The driver was Dennys Rodriguez.
Officer Struble did the usual routine. He got the license and registration for Rodriguez and his passenger. He went back to the patrol car. He ran a records check. Everything seemed fine. He even called for a second officer to head his way.
Eventually, Struble walked back to the Mountaineer and handed Rodriguez a written warning. At that point, the "mission" of the traffic stop—addressing the swerve onto the shoulder—was basically done.
But then things got weird.
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Struble didn't tell them they were free to go. Instead, he asked for permission to walk his drug-sniffing dog around the car. Rodriguez said no. Most people don't realize they can say no, but he did.
Even though the traffic business was finished, the officer ordered Rodriguez out of the car. They sat there and waited. They waited about seven or eight minutes for that second officer to arrive. Once backup was there, Struble walked the dog around the vehicle. The dog alerted. The police found a large bag of methamphetamine.
The "De Minimis" Trap
When the case went to court, the lower courts basically shrugged. They said, "Look, it was only seven or eight minutes. That’s a de minimis intrusion." That's just fancy lawyer-speak for "it’s too small to matter."
The Eighth Circuit Court of Appeals thought that as long as the overall stop was "reasonable," adding a few minutes for a dog sniff wasn't a big deal.
The Supreme Court disagreed. Loudly.
In a 6-3 decision led by Justice Ruth Bader Ginsburg, the Court essentially told law enforcement that a traffic stop isn't a blank check for time. Rodriguez v. United States established a very sharp line: once the tasks tied to the traffic infraction are—or reasonably should have been—completed, the authority to detain you ends.
Period.
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Why Rodriguez v. United States changed everything
Before this ruling, police departments often felt they had a "buffer" of time. If a stop took 20 minutes, and the ticket only took 15, they figured those extra five minutes were "free" for investigative hunches.
Ginsburg’s opinion blew that up.
She argued that a traffic stop is like a Terry stop (a brief investigative detention). Its duration is linked to its "mission." What is that mission?
- Checking the driver’s license.
- Checking for outstanding warrants.
- Inspecting registration and insurance.
- Issuing the actual ticket or warning.
A dog sniff? That’s not for traffic safety. That’s for "detecting evidence of ordinary criminal wrongdoing." Because a dog sniff isn't part of the traffic mission, the officer can’t prolong the stop by even one second to do it unless they have a separate, "reasonable suspicion" that drugs are in the car.
The "Diligence" Factor
One thing people get wrong about this case is thinking there’s a specific stopwatch time. There isn't. There is no rule saying "a stop must last 12 minutes."
Instead, the Court looks at officer diligence.
If an officer is slowly typing with one finger to stall for time while the K9 unit rushes to the scene, they are violating the Fourth Amendment. If they finish the ticket but hold your license while they ask twenty questions about your travel plans to try and trip you up, they might be crossing the line.
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The "critical question," as the Court put it, isn't whether the sniff happens before or after the ticket is handed over. It’s whether the sniff adds time to the stop.
Where the Law stands in 2026
Since the 2015 ruling, we've seen a lot of "workarounds" from law enforcement.
One common tactic is "task-shifting." If an officer has a second person in the car, they might have one officer write the ticket while the other walks the dog. Since the dog sniff is happening simultaneously with the ticket writing, it doesn’t "prolong" the stop. In that scenario, it’s usually legal under the Illinois v. Caballes precedent.
However, the Rodriguez v. United States rule remains the gold standard for defense attorneys. If the bodycam footage shows the officer finished the paperwork, put it in their pocket, and then sat around for three minutes waiting for a K9, that evidence—even if they find ten kilos of meth—might be thrown out under the "fruit of the poisonous tree" doctrine.
Actionable insights for your next drive
Knowing your rights is half the battle, but using them effectively requires a bit of nuance.
- Ask the "Magic" Question: If the officer hands you your documents and keeps talking, you can calmly ask, "Am I free to go?" If they say "No," they must have a reasonable suspicion of a crime to keep you there.
- Consent is Everything: If an officer asks, "Do you mind if I walk my dog around the car?" they are asking for your consent because they likely don't have the legal right to do it otherwise. You have the right to say no.
- Watch the Clock: If you are ever in this situation, take a mental note of the time. When did they take your license? When did they give it back? If the stop feels artificially long, that's something your lawyer will want to know.
- Silence is Golden: You don't have to answer questions about where you are coming from or where you are going. Often, officers use these questions to find "inconsistencies" that they then use to claim "reasonable suspicion" to prolong the stop.
The legacy of Rodriguez v. United States is simple: your constitutional rights don't have a "timer" that allows for minor violations. A violation is a violation, whether it lasts seven minutes or seven hours.
Next time you see those lights, remember that the officer's "mission" has a very specific end point. Once they’ve dealt with the tail light or the speeding, their legal clock has run out.
If you believe a stop was unlawfully prolonged, your next step is to secure the police report and any available dashcam or bodycam footage. These records provide the timestamped evidence necessary to prove a "Rodriguez violation" in court, which can lead to the suppression of evidence found during an illegal extension of the stop.