United States v. Morales, 961 F.3d 1086

At ~1:00 a.m. on March 9, 2019 Officer Mitchell Phillips stopped Julian Trujillo Morales’s Toyota for using fog lamps. The driver and one passenger produced licenses but not proof of insurance.
Officer Phillips ran an OLETS check, interviewed Morales and passenger Victor Ybarra Robles; Morales admitted prior drug convictions and exhibited nervousness; the two gave inconsistent accounts of their destination and relationship. By ~10 minutes into the stop Phillips had developed reasonable suspicion of drug trafficking.
From minutes 10–17 Phillips further questioned the passenger. At minute 17 Phillips called EPIC (a national database) to check border-crossing and criminal-history information; the call involved an ~8.5 minute hold and totaled ~15 minutes (until minute 32). Phillips retained the licenses during the call.
At minute 32 Phillips returned the licenses, said he would not issue a citation, asked for and received consent to search the vehicle; the search uncovered 4.11 kg of methamphetamine and both men were arrested.
The district court granted Morales’s motion to suppress, concluding the 15-minute EPIC call impermissibly prolonged the detention even though the court found the officer had developed reasonable suspicion before the call.
The Government appealed; the Tenth Circuit reversed, holding the EPIC check was a reasonable, diligent measure narrowly tailored to confirm or dispel drug-trafficking suspicion and did not unreasonably extend the stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 15-minute EPIC database call unreasonably prolonged the traffic stop	Morales: the EPIC call was unnecessary and unreasonably delayed the stop; officer gave no adequate justification for detaining him during the call	Government/Phillips: EPIC could verify/supplement OLETS and witnesses’ statements about border crossings and criminal history; calling EPIC was a diligent, reasonable step to confirm suspicion	Court: The EPIC call was reasonable in scope and duration; it was a diligent means to confirm/dispel suspicion and did not unlawfully prolong the seizure
Whether officer’s subjective intent or brief inactivity during the call makes detention unreasonable	Morales: officer said he intended to ask for consent earlier but delayed 25 minutes, and did not perform other investigative tasks while EPIC was on hold	Government: officer’s subjective motives and temporary lack of other tasks are irrelevant; objective reasonableness governs	Court: Subjective intent is irrelevant; evaluating the objective facts at the time, the EPIC call was permissible and sufficiently timely

Terry v. Ohio, 392 U.S. 1 (established investigatory-stop standard)
Whren v. United States, 517 U.S. 806 (traffic stops subject to Fourth Amendment reasonableness)
United States v. White, 584 F.3d 935 (continued detention must be no longer than necessary to confirm or dispel suspicion)
United States v. Cash, 733 F.3d 1264 (reasonable-suspicion standard is objective; approving short detention to verify information)
United States v. Paetsch, 782 F.3d 1162 (no rigid time limit; diligence in pursuing verification is key)
United States v. Moore, 795 F.3d 1224 (returning license ends routine traffic stop absent new reasonable suspicion)
United States v. Santos, 403 F.3d 1120 (criminal history and border crossings relevant to drug-trafficking suspicion)
United States v. Soto-Cervantes, 138 F.3d 1319 (upholding extended detention while officers awaited verification of immigration status)
United States v. Fonseca, 744 F.3d 674 (approving officers’ use of dispatch/database checks to confirm warrants and related info)