We use both our own and third-party cookies for statistical purposes and to improve our services. If you continue to browse, we consider that you accept the use of these.
  • Celebrating 20 Years of Training Excellence 2004-2024

Prolonged Detention

The U.S. Supreme Court last week addressed whether an otherwise completed traffic stop is unreasonable when prolonged for a dog sniff. Rodriguez v. U.S. (2015) 135 S.Ct. 1609, addressed whether a dog sniff conducted after completion of a routine traffic stop, without reasonable suspicion, violated the 4th Amendment and found that it did.


A K-9 officer testified that he saw Rodriguez’ car swerve onto the shoulder of the road briefly. The officer testified that he stopped defendant because this was a traffic violation. The officer approached the car. Defendant was driving and had a passenger. The officer got license, reg, and proof of insurance. He also collected the passenger’s information. The officer returned to his car to run a records check on Rodriguez and the passenger. When he returned to the car, he asked Rodriguez to come back to his police car. When Rodriguez was told he didn’t have to exit the vehicle and go to the officer’s car, he didn’t. The officer wrote a warning.

The officer again went to the car. He explained the warning to Rodriguez and returned both individual’s documents. At that point, the officer testified that all of the business was taken care of. The officer testified that he did not consider Rodriguez free to leave. The officer requested consent to have his dog “walk around” the defendant’s car. Rodriguez refused. The officer then ordered Rodriguez to turn off his car and get out.

A fill officer arrived and the officer walked his dog around the car. The dog alerted to the presence of narcotics. Seven to eight minutes passed from the time of the citation until the dog hit on the car.

Officers found methamphetamine in the vehicle. The defendant moved to suppress the evidence as the officer lacked reasonable suspicion to conduct the dog search.


The Supreme Court took the case to decide whether police may extend a completed traffic stop, without reasonable suspicion, to conduct a dog search.


The Court reiterated that a car stop is analogous to a pedestrian stop. The stop can last no longer than is necessary to address the traffic violation. Anything longer than that is a problem.

Running Raps, clearing up checks regarding the suspect, is lawful. The officer, however, may not extend the stop absent reasonable suspicion. The Court drew a distinction between the stop and the dog sniff. The dog sniff is not related to roadway safety and is not part of the car stop. The Court made clear that the inquiry is not when the dog sniff happen, but rather whether the investigation unlawfully extends the stop.

The court made clear that the officers may prolong a stop when they have reasonable suspicion to detain. The court did say, however, there may be cases when the suspect may be detained when officers have reasonable suspicion to detain.


  • Incredible training with amazing real world instruction. I have been taking law enforcement classes for over 30 years and by far this is the best presented and most useful.

    —Det. Brian Dale, Portland Police Bureau
  • Instructional style is engaging and highly effective.

    —George Laing, Fire Prevention Captain, Investigator
  • It not often that you go to a training that you really, really want to pay attention to. Because of the high quality information and style of presentation, I knew that if I looked away I was going to miss out.

    —Quinten Graves, Oregon State Police
  • This training provided the useful tools necessary for assessing the veracity of a suspected child abuser, which goes a long way in helping to protect children.

    —Sunny Burgan, MSSW, LCSW, Social Work Supervisor, Santa Clara County DFCS
  • I highly recommend this training for any Probation staff who have the necessity to interview/interrogate individuals for investigation purposes.

    —R. Bret Fidler, Santa Clara County Probation Department
  • Your training gave me the confidence and tools to interview the suspect for over 5 hours and to bring a closure to the case.

    —Daniel Phelan, San Jose Police Department
  • I will continue to use and pass on this information because I really believe in the instructors and their approach.

    —Kimberly Meyer, Washoe County Sheriff's Department
  • This was, by far, one of the most useful training classes I've attended since becoming an investigator.

    —Steven Aiello, Antioch Police Department
  • Effective teaching teams! The presentation of the material was consistently interesting, and intelligent without being too intellectualized.

    —Michele Keller, Deputy Probation Officer, County of Alameda
  • This was, by far and away the best training I have received in 15 plus years of Law Enforcement. The instructors are experienced, engaging, articulate, and very entertaining. I will be recommending this training to multiple agencies.

    —Mark Paynter, Oregon DOC
  • This training by far has been the most informative and most effective I've attended. The instructors engaged the students in a manner that made me want to speak my opinion, ask questions, and participate.

    —Julio Ibarra, Merced County Sheriff’s Office
  • The information presented was highly relevant to my job and was presented in a manner that was organized and very easy to digest.

    —Michael McGarvey, California State Prison, San Quentin
  • Your training has made the greatest and most direct impact on my assignment of any training class that I've taken.

    —Ken Gelskey, National City Police Department