United States v. Gregory Sanford, 2015 U.S. App. LEXIS 20503

Background

At 12:00 a.m. on Feb. 28, 2012, an Illinois trooper stopped a rental car on I‑55 for speeding (83 mph). Two passengers included Gregory Sanford. The car had been rented in Peoria 12 hours earlier and none of the occupants were authorized drivers on the rental contract.
The trooper ran computer criminal-history checks on the three occupants and learned Sanford and another passenger had gang/drug‑related records; the trooper then requested a drug‑detection dog.
While waiting for the dog (total elapsed time from stop to dog alert: 26–27 minutes), the trooper obtained additional evasive statements from the driver; the dog alerted and the trunk was opened, revealing 1.5 kg of cocaine.
Sanford pleaded guilty to possession with intent to distribute after the district court denied his motion to suppress; his plea was conditional to preserve his right to appeal the suppression ruling. He also appealed certain conditions of supervised release.
The district court denied suppression primarily on (1) standing grounds (Sanford as a passenger/unauthorized user lacked an expectation of privacy in the rental car) and (2) the continued seizure while awaiting the dog was supported by growing reasonable suspicion. The Seventh Circuit affirmed in part (conviction), reversed in part (supervised‑release conditions), and remanded.

Issues

Issue	Sanford's Argument	Government's Argument	Held
Standing to challenge search of rental car	Sanford lacked rental authorization but argued he had a privacy/seizure interest as a passenger and former driver	Trooper argued unauthorized renter/borrower lacks a sufficient expectation of privacy	Court avoided resolving rental‑car standing; held Sanford has standing to challenge the seizure of his person during the traffic stop (Brendlin line)
Lawfulness of prolonging stop to await drug dog	The prolonged detention to wait for a dog sniff rendered the seizure unreasonable under Rodriguez	Trooper argued reasonable suspicion (rental third‑party, known drug corridor, occupants’ evasive behavior, criminal‑history hits) justified delay	Court held reasonable suspicion existed to justify an ~8‑minute prolongation to await the dog; suppression denied
Legitimacy of criminal‑history check during stop	Sanford contended checking passengers’ records was beyond scope of a traffic stop	Government relied on precedent permitting checks during stops and the minimal intrusion/time	Court held computer criminal‑history checks were permissible and contributed to reasonable suspicion
Conditions of supervised release	Sanford argued many written conditions were invalid/unjustified	Government conceded defects in supervised‑release conditions and agreed remand was appropriate	Court reversed and remanded for reconsideration of supervised‑release conditions (prison term remains unchanged due to binding Rule 11(c)(1)(C) plea)

Key Cases Cited

Rakas v. Illinois, 439 U.S. 128 (recognition of Fourth Amendment privacy interests beyond ownership)
Brendlin v. California, 551 U.S. 249 (passenger has standing to challenge seizure of person during traffic stop)
Rodriguez v. United States, 575 U.S. 348 (prolonging a traffic stop to conduct a dog sniff requires independent reasonable suspicion)
United States v. Haywood, 324 F.3d 514 (unauthorized driver of rented car and standing analysis)
United States v. Walton, 763 F.3d 655 (Seventh Circuit discussion of rental‑car standing)
United States v. Pettit, 785 F.3d 1374 (Tenth Circuit: reasonable to wait for drug dog where reasonable suspicion exists)
United States v. Lyons, 486 F.3d 367 (Eighth Circuit: lengthy wait for dog reasonable when supported by suspicion)
United States v. Wellons, 32 F.3d 117 (Fourth Circuit: rental‑car unauthorized driver and impound/notification practice)
United States v. Johnson, 765 F.3d 702 (requirements for imposing supervised‑release conditions)
United States v. Thompson, 777 F.3d 368 (need to justify supervised‑release conditions at sentencing)