Alonzo Miller v. United States

When a police officer stops a citizen for a traffic violation, he may not prolong the duration, or expand the scope, of the stop unless he develops reasonable suspicion of criminal activity other than the initial traffic violation. Rodriguez v. United States, 575 U.S. 348, 354-55 (2015). An officer may not rely on an unparticularized hunch to support reasonable suspicion but must be able to point to “specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” Terry v. Ohio, 392 U.S. 1, 21 (1968). “The scheme of the Fourth Amendment becomes meaningful only when it is assured that at some point the conduct of those charged with enforcing the laws can be subjected to the more detached, neutral scrutiny of a judge who must evaluate the reasonableness of a particular search or seizure in light of the particular circumstances.” Id. This Court has always required reviewing courts to make reasonable suspicion determinations by looking at the “totality of the circumstances.” United States v. Arvizu, 534 U.S. 266, 273 (2002). The question presented is: Whether a reviewing court fails to perform its function when it disregards facts that undermine or negate an inference of criminality when determining whether a law enforcement officer developed reasonable suspicion that would justify extending a traffic stop?