United States v. Shane Nault, 41 F.4th 1073

Police were alerted that a red GMC truck registered to Joei Ross (who had an outstanding arrest warrant) was parked and idling at a Havre, Montana gas station; Shane Nault was in the driver’s seat.
Officer Chroniger boxed the truck, approached, identified Nault, and—about 20 seconds after contact—asked for license, registration, and proof of insurance (which he described as routine).
While Nault searched for documents, Chroniger noticed signs (fidgeting, constricted pupils, sweating) that led him to begin a DUI investigation; a pat-down produced brass knuckles and a glass marijuana pipe and Nault was arrested.
A drug-task-force canine later alerted to the truck’s driver-side door; an affidavit for a search warrant also recounted a prior controlled buy of meth from Nault from the same truck.
The executed warrant yielded a pistol and over 500 grams of methamphetamine. Nault moved to suppress and to traverse (requesting a Franks hearing); the district court denied both motions. The Ninth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer unconstitutionally prolonged the stop by requesting driver documents after learning Ross was not present	Nault: asking for license/registration after the warrant-subject was absent unlawfully extended the seizure beyond its mission	Government: document request was part of the stop’s mission (routine traffic-safety inquiry); moreover independent reasonable suspicion of DUI arose	Court: request fell within the mission of a vehicle stop (routine inquiries); once signs of impairment manifested, independent reasonable suspicion supported continued detention — suppression denied
Whether Nault made a substantial showing entitling him to a Franks hearing challenging warrant affidavit omissions about the canine sniff	Nault: expert report (from a different case) showed the canine’s prior alert was unreliable, so affidavit misled magistrate and omitted material facts	Government: expert evidence pertained to a different, later incident; affidavit’s statement that the dog “proven reliable in prior incidents” was not shown to be intentionally or recklessly false or material	Court: Nault failed to make the required substantial preliminary showing of intentional/reckless falsehood or material omission — Franks hearing denied

Rodriguez v. United States, 575 U.S. 348 (2015) (routine inquiries during a traffic stop—license, registration, insurance—can be part of the stop’s mission)
Terry v. Ohio, 392 U.S. 1 (1968) (framework for investigative stops under Fourth Amendment)
Delaware v. Prouse, 440 U.S. 648 (1979) (random stops to check driver credentials are unconstitutional without reasonable suspicion)
Brendlin v. California, 551 U.S. 249 (2007) (passenger is seized during a traffic stop)
United States v. Landeros, 913 F.3d 862 (9th Cir. 2019) (officer inquiries during stop must be part of mission or supported by independent reasonable suspicion)
United States v. Gorman, 859 F.3d 706 (9th Cir. 2017) (stop unconstitutionally prolonged if it exceeds time needed for routine tasks)
United States v. Evans, 786 F.3d 779 (9th Cir. 2015) (records checks related to vehicle safety are within stop’s mission)
United States v. Yancey, 928 F.3d 627 (7th Cir. 2019) (ensuring a licensed driver for an arrested driver’s vehicle may be part of the mission)
Franks v. Delaware, 438 U.S. 154 (1978) (standard for obtaining a hearing to challenge warrant affidavit truthfulness)
United States v. Norris, 942 F.3d 902 (9th Cir. 2019) (Franks substantial preliminary showing standard)