Commonwealth v. Cordero, 477 Mass. 237

On Feb. 19, 2015, State Trooper Pack followed a Toyota Camry for ~5 miles for broken tail/brake lights and illegal window tint; onboard computer confirmed valid registration, license, insurance, and no outstanding warrants.
Trooper stopped the car, identified the driver as the registered owner, tested window tint, discussed the broken lights, and obtained the driver's license; the trooper completed the routine tasks tied to the traffic stop.
During the stop the driver appeared nervous and gave evasive answers about his travel; passenger also appeared nervous. Trooper asked for consent to search and suspected drug activity and called for a canine unit.
The driver was frisked (consenting after being told he would be handcuffed), $1,900 found on his person; he later volunteered marijuana from the glove box which was retrieved with permission.
After additional officers arrived, the driver ultimately consented to a trunk search; officers found ~2,000 suspected heroin bags and arrested him. The stop lasted 40–45 minutes.
The Superior Court denied the motion to suppress; the SJC took direct appellate review and reversed, holding the post‑traffic investigative detention was unlawful absent reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers lawfully prolonged a traffic stop to investigate unrelated drug activity	Troopers may investigate incriminating facts arising during a stop and had reasonable suspicion from nervousness, evasive answers, source‑city origin, and criminal record	Once traffic‑related tasks were completed and no specific, articulable facts pointed to crime, defendant had to be allowed to leave; subsequent seizure is fruit of the poisonous tree	Court held detention was unlawfully prolonged: after routine tasks finished there was no reasonable suspicion to investigate drugs, so evidence seized post‑completion must be suppressed
Whether consent obtained during the extended detention validated the trunk search	Commonwealth: consent and other developments (frisk, statements) justified search	Defendant: consent given during unlawful detention is invalid; consent was tainted by the unconstitutional prolongation	Court held consent obtained during unlawful detention ineffective to cure the constitutional violation; later consent could not validate the trunk search

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic‑stop "mission" limits permissible duration of seizure)
Commonwealth v. Torres, 424 Mass. 153 (1997) (threshold inquiry must end once traffic purpose is satisfied)
Commonwealth v. Feyenord, 445 Mass. 72 (2005) (circumstances can justify expansion of stop when specific suspicious facts arise)
Commonwealth v. Amado, 474 Mass. 147 (2016) (standard of review for motions to suppress)
Wong Sun v. United States, 371 U.S. 471 (1963) (fruits of unlawful detention suppressed)
Commonwealth v. Gonsalves, 429 Mass. 658 (1999) (officers may not use stalling tactics to prolong traffic stops)