United States v. Patrick Winters
782 F.3d 289
| 6th Cir. | 2015Background
- Officer Jason Duggan stopped a rental car at 12:04 a.m. for speeding; Winters was the sole passenger and Jessica Harris the driver.
- Officer Duggan discovered the rental was booked in a third party’s name for a short, circuitous Atlanta–Memphis–Chicago itinerary; neither occupant was an authorized driver.
- During questioning both occupants appeared nervous and gave inconsistent, implausible accounts of travel plans; Winters hung up his phone as the officer approached.
- After completing a warning citation at 12:24 a.m., Duggan extended the stop ~4 minutes to fetch his on-scene drug dog; the dog alerted at 12:28 a.m.
- A subsequent search revealed a one-kilogram package of heroin in Winters’s bag; Winters moved to suppress, lost, pleaded guilty conditionally, and appealed the denial of suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was unlawfully extended to conduct a dog sniff | Winters: officer unreasonably prolonged a completed stop to deploy a dog without reasonable suspicion | Government: totality of circumstances produced reasonable, articulable suspicion to extend the stop for a brief dog sniff | Court: reasonable suspicion existed (nervousness + implausible travel plans + suspicious rental arrangement); extension was justified |
| Whether Jardines requires probable cause for a canine sniff of a vehicle during a stop | Winters: Jardines means dog sniffs are "searches" requiring probable cause | Government: Jardines protects the home (trespass rationale) and does not disturb Caballes re: vehicle dog sniffs | Court: Jardines’ trespass/home rationale does not apply to traffic stops; Caballes remains controlling |
| Whether the dog alert provided probable cause to search the vehicle | Winters: (challenged only the sniff/extension; once alerted, issue implicit) | Government: a trained dog’s alert establishes probable cause to search vehicle and containers | Court: Dog alert provided probable cause; search lawful |
| Whether evidence should be suppressed under new precedent | Winters: suppression appropriate if Jardines undermines prior dog-sniff law | Government: officer reasonably relied on existing binding precedent; exclusionary rule not warranted | Court: even if Jardines raised doubts, officer acted in objective good faith relying on precedent; no suppression |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (police may briefly detain based on reasonable, articulable suspicion; detention must be limited in scope and duration)
- Delaware v. Prouse, 440 U.S. 648 (1979) (stopping an automobile is a seizure under the Fourth Amendment)
- Illinois v. Caballes, 543 U.S. 405 (2005) (a canine sniff during a lawful traffic stop generally does not implicate a legitimate privacy interest)
- Florida v. Jardines, 569 U.S. 1 (2013) (use of a drug-detection dog to investigate the home is a search under a trespass/property rationale)
- Arizona v. Johnson, 555 U.S. 323 (2009) (officer inquiries unrelated to the stop do not convert the seizure so long as they do not measurably extend its duration)
- United States v. Place, 462 U.S. 696 (1983) (canine sniffs at airports are not searches under the Fourth Amendment)
- Davis v. United States, 564 U.S. 229 (2011) (evidence obtained in reasonable reliance on binding precedent is not subject to exclusion)
- United States v. Arvizu, 534 U.S. 266 (2002) (reasonable suspicion is evaluated under the totality of the circumstances; courts must avoid dividing factors in isolation)