Wyoming v. William Thomas Mahaffy, V

In Rodriguez v. United States, 575 U.S. 348 (2015), this Court held that the Fourth Amendment requires reasonable suspicion to extend an already-completed traffic stop. It rejected a line of cases that permitted “de minimis” extensions after the tasks of a traffic stop were complete. However, in Arizona v. Johnson, 555 U.S. 323 (2009), this Court held that officers may make unrelated inquiries during a traffic stop “so long as those inquiries do not measurably extend the duration of the stop.” In this case, the Wyoming Supreme Court held Rodriguez required suppression, even though the officer’s unrelated questioning during the traffic stop—including the defendant’s answers—only lasted 27 seconds. The Question Presented is: Did the Rodriguez Court’s rejection of de minimis extensions to traffic stops abrogate or limit Johnson, thereby prohibiting officers from posing any unrelated questions even where the inquiry does not measurably extend the duration of the stop?