By Cate Berenato
On December 14, 2015, in the published case United States v. Williams, the Fourth Circuit overturned the United States District Court for the Middle District of North Carolina’s decision not to suppress evidence police obtained from a search of a car. The Fourth Circuit stated that the Government did not prove that the police had reasonable suspicion to search the defendant’s car.
The issue in this case was whether, based on a totality of circumstance, the police properly delayed defendant to allow for a police dog to search defendant’s car.
The Police Encounter with Mr. Williams
On February 13, 2012, police stopped Mr. Charles Williams, Jr. on Interstate 85 for going 80 miles per hour in a 70 mile per hour zone. Two policemen were involved in the stop. When Mr. Williams refused one police officer’s request to search his car, the officer had Mr. Williams wait for over two minutes while the other police officer brought over his dog to search the car. The dog detected drugs, and the police found cocaine in the car’s trunk. The district court considered four factors to determine that the stop was proper: (1) the defendant was driving in a rental car; (2) the defendant was traveling on a known drug corridor around midnight; (3) Williams’ alleged travel plans were inconsistent with the due date of his rental car; (4) Williams did not provide a permanent home address in New York, despite stating he lived there.
Courts consider the constitutionality of stops through a two-pronged test. First, courts ask whether the officer’s reason for the stop was legitimate. Second, the court considers whether the officer’s actions during the seizure were reasonably related to the basis for the traffic stop. Under the second prong, an officer’s authority to detain ends when the tasks associated with the stops are complete. Because a traffic stop is a seizure under the Fourth Amendment, an officer must have a reasonable, articulable suspicion that criminal activity is afoot if he or she executes an investigatory detention. The reasonable suspicion depends on the totality of the circumstances. This can also turn on the judgment of experienced law enforcement officers.
The Fourth Circuit Was Not Persuaded by the District Court’s Factors
First, the parties do not dispute that the officers met the first prong. In other words, the stop was legitimate because Mr. Williams was speeding. The officers did not meet the second prong because the first officer had already accomplished the purpose of the stop before the second officer allowed his dog sniff Mr. Williams’ car.
Additionally, the factors that the district court considered did not lead to reasonable suspicion. First, the officers did not explain any connection between rental cars and criminal activity. Second, the majority of drivers who drive on the highways that may be drug corridors are innocent. Likewise, neither officer asserted that drug traffickers travel on interstates late at night more frequently than innocent drivers. Third, many innocent drivers extend their rental car agreements in the midst of their trips. Fourth, and finally, neither officer asked Mr. Williams for his permanent address, and neither explained how using a post office box address or living in New York raised suspicions of criminal activities.
Thus, the Fourth Circuit vacated and remanded the district court’s decision.