United States v. Donald Hill
2017 U.S. App. LEXIS 5537
| 4th Cir. | 2017Background
- Officers stopped a car for speeding and crossing a double-solid yellow line; driver Jeremy Taylor exited and the stop began ~6:01 p.m.
- Officer Taylor ran both occupants’ names through DMV and NCIC; NCIC returned an alert that both had drug-trafficking associations and were “likely armed.”
- Officer Taylor began writing two summonses and requested a K-9; he also searched the local PISTOL database, which took several minutes to disambiguate common names.
- Officer McClendon stood at the passenger side and questioned the occupants; after asking three times about drugs or guns, Hill (the passenger) said he had a firearm, at which point officers recovered the weapon.
- The district court found officers credible, concluded the stop lasted about 20 minutes, and denied Hill’s motion to suppress; Hill appealed, arguing the stop was unlawfully prolonged in violation of Rodriguez.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers unlawfully extended the traffic stop beyond tasks tied to the traffic violation | Hill: officers prolonged detention by running extra database searches (PISTOL), requesting a K-9, and by prolonged questioning, without reasonable suspicion or consent | Government: officers acted with reasonable diligence; tasks (ID checks, warrants, PISTOL search, summons-writing, K-9 request) were related to officer safety and the stop’s mission and did not add time beyond what was reasonable | Affirmed: stop was not unreasonably prolonged; district court’s factual findings not clearly erroneous; officers acted with reasonable diligence |
| Whether use of PISTOL during the stop violated the Fourth Amendment | Hill: searching an additional local database was unnecessary and extended the stop | Government: PISTOL is relevant to officer safety and identifying prior contacts; officers need not use least intrusive means | Held: searching PISTOL was reasonable and within scope; not a Fourth Amendment violation |
| Whether officer’s decision to keep one officer at the vehicle and question occupants was lawful | Hill: McClendon’s presence and questioning prolonged and expanded the stop into an investigatory detention | Government: safety concerns (NCIC alert: likely armed) justified allocating duties and asking routine questions; such questioning is permissible if it doesn’t extend the stop | Held: allocation of duties and unrelated questioning were reasonable and did not extend the stop |
| Whether requesting a K-9 unlawfully extended the stop under Rodriguez | Hill: K-9 request was used to extend the detention for a dog sniff after the purpose of the stop was complete | Government: request was contemporaneous with ongoing tasks; dog had not begun sniffing at the time gun was disclosed | Held: request did not prolong the stop; Rodriguez inapplicable because sniff had not occurred after completion of traffic tasks |
Key Cases Cited
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (seizure authority ends when tasks tied to the traffic infraction are completed; even de minimis extensions violate the Fourth Amendment)
- Illinois v. Caballes, 543 U.S. 405 (2005) (K-9 sniff during lawful traffic stop does not violate Fourth Amendment if it does not prolong the stop)
- Arizona v. Johnson, 555 U.S. 323 (2009) (officers may question passengers during a traffic stop; unrelated inquiries permitted if they do not extend the stop)
- United States v. Digiovanni, 650 F.3d 498 (4th Cir. 2011) (reasonable duration of a traffic stop judged under totality of circumstances; no mathematical precision required)
- United States v. Palmer, 820 F.3d 640 (4th Cir. 2016) (officers must be reasonably diligent and may use least intrusive means reasonably available; officers entitled to inquire into criminal records for safety)