United States v. Charles Williams, Jr., 808 F.3d 238

In Feb. 2012 deputies stopped a rental Hyundai for speeding on I‑85; driver Charles Williams sat in the patrol car while an officer prepared a written warning.
After Williams passed a breathalyzer and received the written warning (stop tasks completed), one deputy asked to search the car; Williams refused consent.
About 1 minute 23 seconds after the warning, a deputy said “hold on” and deployed a drug‑detection dog; the dog circled and alerted to the trunk ~2 minutes 40 seconds later, leading to discovery of crack cocaine.
At an initial suppression hearing the district court denied suppression based on five factors (rental car, known drug corridor, late hour, rental-return inconsistency, inconsistent statements between vehicles) and alternatively as a de minimis delay.
A subsequently produced patrol‑car video (Soles Video) undermined the inconsistent‑statements factor; after a reconsideration hearing the court re‑denied suppression relying on four factors and again on de minimis delay.
On appeal the government conceded Rodriguez forecloses the de minimis rationale; the Fourth Circuit evaluated whether the four remaining factors, alone or in combination, supplied reasonable, articulable suspicion to extend the stop for a dog sniff.

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (Government)	Held
Whether officers had reasonable, articulable suspicion to extend a completed traffic stop to conduct a dog sniff	The four factors relied on by the district court (rental car; known drug corridor; travel plans inconsistent with rental return; lack of permanent address) are each weak and together do not eliminate a substantial portion of innocent travelers; deputies offered no articulation linking those facts to criminality	The totality of the four factors provided reasonable suspicion to detain briefly for a dog sniff (and the government had previously relied on a de minimis‑delay theory, which it later conceded is foreclosed by Rodriguez)	The Fourth Circuit held there was no reasonable, articulable suspicion; the extension for the dog sniff violated the Fourth Amendment, so Williams’s conviction and sentence were vacated and remanded

Whren v. United States, 517 U.S. 806 (traffic stop is a Fourth Amendment seizure)
Terry v. Ohio, 392 U.S. 1 (standard for investigative detentions)
Ornelas v. United States, 517 U.S. 690 (reasonable‑suspicion reviewed de novo with factual findings for clear error)
Arizona v. Johnson, 555 U.S. 323 (application of Terry to traffic stops)
Rodriguez v. United States, 135 S. Ct. 1609 (officers may not extend a completed traffic stop to conduct a dog sniff absent reasonable suspicion)
United States v. Arvizu, 534 U.S. 266 (totality‑of‑circumstances test for reasonable suspicion)
United States v. McCoy, 513 F.3d 405 (facts must eliminate a substantial portion of innocent travelers)
United States v. Digiovanni, 650 F.3d 498 (similar factors insufficient for reasonable suspicion)
United States v. Farrior, 535 F.3d 210 (prior Fourth Circuit case discussing de minimis rule for dog sniffs—later superseded by Rodriguez)
United States v. Boyce, 351 F.3d 1102 (rental car + known corridor + late return insufficient alone to establish reasonable suspicion)
United States v. Santos, 403 F.3d 1120 (implausible travel plans can contribute but not dispositive without more)