United States v. Jacques Gholston, 1 F.4th 492

Officer Erik Cowick stopped Jacques Gholston at ~12:17 a.m. for turning without signaling; Cowick had a prior (months‑old, anonymous/informal) tip suspecting Gholston of selling meth from his green pickup.
Cowick handcuffed and frisked Gholston, obtained identifying information (manually entered after Gholston said his ID was in the truck), and checked license/dispatch; other officers arrived.
Cowick contacted a K9 handler (Saalborn/sam12) ~6–7 miles away and repeatedly messaged/urged the handler to hurry while also asking another officer to retrieve a prior Notice of Violation and to “take your time.”
Cowick printed a warning for the turn‑signal violation at 12:32 a.m.; after realizing he had not asked about proof of insurance he started a second ticket. The dog arrived while the second ticket was printing, alerted, and officers found ~9 grams of methamphetamine.
Gholston moved to suppress arguing Cowick unreasonably prolonged the stop to wait for the K9; a magistrate found an extension but concluded reasonable suspicion existed; the district court disagreed the stop was unreasonably extended and denied suppression. The Seventh Circuit affirmed.

Issue	Gholston (Plaintiff) Argument	Cowick/Government (Defendant) Argument	Held
Whether the traffic stop was unreasonably prolonged to await a K9 and thus violated the Fourth Amendment	Cowick took unrelated actions (handcuffing/frisk, repeated texts, delaying insurance request) to prolong the stop until the K9 arrived	Delays were minor, attributable to legitimate tasks or innocent mistakes (manual entry of ID, belated insurance oversight); Cowick was diligently working on tickets	Court held the district court did not clearly err: the stop was not unreasonably extended and suppression was properly denied
Whether officers had reasonable suspicion to continue detaining Gholston based on the informant tip and on‑scene observations	The tip was stale, vague, and uncorroborated and therefore insufficient to justify continued detention	Magistrate believed the tip and on‑scene observations supplied reasonable suspicion; government advanced related factual points	The majority did not rely on reasonable‑suspicion grounds (affirmance rested on no unreasonable extension); magistrate had found suspicion but the panel affirmed because there was no unconstitutional prolongation

Illinois v. Caballes, 543 U.S. 405 (2005) (a lawful traffic stop may not be prolonged beyond time reasonably required for its mission)
Rodriguez v. United States, 575 U.S. 348 (2015) (a stop may not last longer than necessary to effectuate its purpose; side‑inquiries require independent reasonable suspicion)
United States v. Lopez, 907 F.3d 472 (7th Cir. 2018) (focus on whether detention exceeded time necessary for the underlying investigation rather than counting minutes)
United States v. Williams, 731 F.3d 678 (7th Cir. 2013) (standard of review for suppression rulings: factual findings for clear error, legal conclusions de novo)
Whren v. United States, 517 U.S. 806 (1996) (pretextual stops permissible so long as probable cause for a traffic violation exists)
United States v. Sharpe, 470 U.S. 675 (1985) (authority for seizure ends when tasks tied to the traffic stop are—or reasonably should have been—completed)
United States v. Cole, 994 F.3d 844 (7th Cir. 2021) (discusses delays in pretextual stops and related reasonable‑suspicion principles)