United States v. Jamel Hurtt, 31 F.4th 152

Around 2:00 a.m., officers Cannon and Gonzalez stopped a pickup for traffic violations; three occupants were in the truck and officers detected the smell of alcohol.
Gonzalez began a field sobriety inquiry of the driver behind the truck (an on-mission DUI investigation).
Cannon approached the driver’s open door, climbed partially into the cab and kneeled on the front seat while the driver was being tested.
Gonzalez paused the sobriety test to assist because Cannon was in a vulnerable position inside the vehicle.
While Cannon was in the cab, Hurtt (rear passenger) twice reached toward a bucket; Cannon ordered him out, frisked him, and found a loaded handgun.
The district court denied Hurtt’s suppression motion; the Third Circuit reversed, holding the stop was unlawfully extended by off‑mission conduct and suppressing the gun evidence.

Issue	Hurtt's Argument	Government's Argument	Held
Was the traffic stop unlawfully extended?	Officers detoured from the DUI/traffic mission, causing an unlawful extension.	The DUI investigation was ongoing; actions were related to officer safety and the mission.	The stop was unlawfully extended when Gonzalez paused the DUI test to address Cannon’s off‑mission conduct.
Was Cannon’s entry into the truck a lawful on‑mission safety measure?	Cannon’s entry was off‑mission and created the safety risk; not justified.	Entry was to engage passengers and maintain safety during the stop.	Cannon’s climbing into the cab was off‑mission and created a police‑created exigency that cannot justify extension.
Could Gonzalez permissibly pause the sobriety test to ensure partner safety?	Pausing was an off‑mission detour caused by Cannon and thus unlawful.	Ensuring officer safety justified a brief pause to assist partner.	Pausing the test for a safety concern created by off‑mission conduct violated Rodriguez; the pause was not justified.
Was there reasonable suspicion to frisk/search Hurtt before the frisk?	No reasonable suspicion existed when the stop was extended; thus the frisk/search was unlawful.	Officers point to furtive, evasive movements and high‑crime area to justify suspicion.	No lawful reasonable‑suspicion basis supported the frisk at the time it occurred because the stop had been unlawfully extended by police conduct.

Rodriguez v. United States, 575 U.S. 348 (stops may not be extended beyond mission without reasonable suspicion)
United States v. Green, 897 F.3d 173 (3d Cir. 2018) (two‑step Rodriguez analysis; identify Rodriguez moment then assess reasonable suspicion)
Whren v. United States, 517 U.S. 806 (traffic stop is a Fourth Amendment seizure; initial stop requires probable cause)
Rakas v. Illinois, 439 U.S. 128 (standing/legitimate expectation of privacy principles)
Kentucky v. King, 563 U.S. 452 (police‑created exigency doctrine)
Pennsylvania v. Mimms, 434 U.S. 106 (officer safety can justify some on‑mission intrusions like ordering driver out of car)