United States v. Gomez-Arzate, 981 F.3d 832

Deputies stopped a Kia Soul for swerving and touching the solid white shoulder line twice; Deputy Mora noted a misaligned front tire and an overwhelming air-freshener odor.
Language barrier prompted a bilingual deputy (Mauricio) to assist; during the stop deputies checked license/registration and communicated reasons for the stop.
About 11 minutes in deputies asked to check the VIN and briefly questioned defendants about travel plans; a warning citation for careless driving was issued and documents returned around 16 minutes.
After being told they were free to go, both men agreed to additional questioning and signed Spanish consent-to-search forms (around 33 minutes after stop); deputies searched the car for a total of 90 minutes.
Deputies removed panels and discovered two tape-wrapped packages containing ~7 pounds of methamphetamine; defendants pleaded guilty conditionally and appealed denial of suppression motions; Tenth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Initial justification for stop	Stop lacked reasonable suspicion	Swerving/touching line twice gave reasonable suspicion under NM lane statute	Stop was justified at inception
Whether VIN check and travel questions (minutes 11–16) unlawfully prolonged stop	Paperwork was complete; stop effectively ended, so VIN/questions unlawfully extended detention	VIN check and travel questions are ordinarily within traffic-stop scope	Court: this segment was improperly prolonged but no suppression because not the but-for cause of discovery and consent would have been given
Whether post-citation questioning was a consensual encounter or unlawful detention	Returning documents did not transform encounter; defendants still detained absent reasonable suspicion	Deputies told defendants they were free to go and obtained voluntary agreement; deputies also had articulable suspicion (air freshener, document discrepancies, implausible travel story)	Court: encounter was consensual; alternatively, deputies had reasonable suspicion to continue questioning
Validity and scope/duration of consent to search	Consent was coerced or consent scope was exceeded by dismantling and long 90-minute search	Defendants voluntarily consented (signed Spanish forms); general consent extends to whole car; removal/replacement of parts was minor	Court: consent was voluntary; search scope and duration reasonable; limited dismantling permissible and lawful

Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable-suspicion requires a particularized, objective basis)
Rodriguez v. United States, 575 U.S. 348 (2015) (traffic-stop mission ends when tasks tied to the traffic infraction are completed)
United States v. Chavira, 467 F.3d 1286 (10th Cir. 2006) (but-for causation required to suppress evidence as fruit of unlawful conduct)
United States v. Bradford, 423 F.3d 1149 (10th Cir. 2005) (stop may become consensual after documents are returned)
United States v. Spence, 397 F.3d 1280 (10th Cir. 2005) (factors for assessing coercive effect of police conduct)
United States v. Pettit, 785 F.3d 1374 (10th Cir. 2015) (vehicle registered to an absent third party can indicate trafficking)
United States v. Osage, 235 F.3d 518 (10th Cir. 2000) (officer may not destroy or render completely useless a container without explicit consent or other justification)
United States v. Rosborough, 366 F.3d 1145 (10th Cir. 2004) (scope/duration of consent judged by what a reasonable person would understand)
United States v. Warwick, 928 F.3d 939 (10th Cir. 2019) (signed consent form is strong evidence of voluntary consent)
United States v. Cortez, 965 F.3d 827 (10th Cir. 2020) (stop cannot be prolonged absent consent or independent reasonable suspicion)