United States v. Charles Ahumada, 858 F.3d 1138

On Dec. 29, 2014, ND trooper Jeremie Meisel stopped a car on I‑94 for speeding; Charles Ahumada was a passenger and Frank Villa the driver.
Meisel issued Villa a warning and asked for consent to search or for a dog sniff; Villa refused consent, so Meisel conducted a dog sniff with a drug‑detection dog.
The dog alerted at the driver’s door about 8½ minutes after the warning was issued; Meisel searched the vehicle, found syringes in the trunk, arrested Villa, and later officers recovered over 4.5 pounds of heroin from the trunk roof after towing and further searching.
Ahumada was indicted with Villa for conspiracy to distribute heroin and possession with intent to distribute heroin; Ahumada moved to suppress the heroin as the product of an unconstitutional prolongation of the traffic stop.
The district court denied suppression, relying on then‑binding circuit precedent allowing brief (de minimis) extensions; a jury convicted Ahumada and he appealed, arguing Rodriguez v. United States required suppression and that evidence was insufficient for possession with intent to distribute.
The Eighth Circuit affirmed, holding suppression was not warranted because the trooper reasonably relied on binding circuit precedent permitting short extensions and that the sufficiency challenge misconstrued the elements of the charged offense.

Issue	Ahumada's Argument	Government's Argument	Held
Whether the traffic stop was unconstitutionally prolonged by a dog sniff after the warning	The dog sniff extended the stop beyond the time needed for the speeding warning, violating Rodriguez and requiring suppression	Trooper acted in reasonable, good‑faith reliance on binding Eighth Circuit precedent that de minimis extensions under 10 minutes are permissible, so exclusionary rule does not apply	Denied suppression; reliance on binding precedent (pre‑Rodriguez) made the brief extension permissible
Whether evidence was sufficient to convict Ahumada of possession with intent to distribute heroin	Argues gov’t failed to prove an element (claimed required proof of intentional transfer to another)	The crime requires knowing possession and intent to distribute; transfer is an element of distribution, not possession with intent to distribute	Sufficiency challenge fails; transfer is not an element of the charged offense

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic stop cannot exceed time needed to handle the matter absent reasonable suspicion)
Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule inapplicable when officers act in objectively reasonable reliance on binding precedent)
United States v. Englehart, 811 F.3d 1034 (8th Cir. 2016) (Eighth Circuit precedent treating seizures under ten minutes as de minimis and permissible pre‑Rodriguez)
Herring v. United States, 555 U.S. 135 (2009) (limits on the exclusionary rule where official error is not deliberate or negligent)
United States v. Jones, 269 F.3d 919 (8th Cir. 2001) (Eighth Circuit precedent relied on by state court in State v. Fields regarding post‑stop detention)
Draper v. United States, 358 U.S. 307 (1959) (addressing reliability of informant information and its role in establishing probable cause)