Joshua Coleman v. Louisiana

A traffic stop can be “unlawful if it is prolonged beyond the time reasonably required to complete the mission of issuing a traffic ticket.” Illinois v. Caballes, 543 U.S. 405, 125 S.Ct. 834, 160 L.Ed. 842 (2005). Even a de minimis detention to conduct on-scene investigation into other crimes, including a dog sniff, can violate the Fourth Amendment. Rodriguez v. United States, 575 U.S. 348, 135 S.Ct. 1609, 191 L.Ed.2d 492 (2015). Thus, the question becomes: Does the Fourth Amendment protection against unreasonable seizures tolerate a dog sniff which prolongs a stop, which occurs after all purposes for the initial stop have concluded without citation, and which occurs in the absence of reasonable suspicion or probable cause?