United States v. Theodore Clark, III
902 F.3d 404
| 3rd Cir. | 2018Background
- Officer Bradley stopped a minivan at night for traffic violations; driver Donald Roberts produced license and insurance but could not find registration.
- Bradley ran a computer check using the plate; it confirmed the license was valid, the vehicle was registered to a woman at the same address on Roberts’ license, and Roberts had a prior drug-related criminal record.
- After the computer check, Bradley asked Roberts several questions about his criminal history; Roberts became confused and was asked to step out of the vehicle.
- Bradley then questioned passenger Theodore “Tyrone” Clark III; after smelling marijuana from the passenger side, officers patted down Clark, who revealed a handgun and a marijuana cigarette.
- Clark was indicted federally under 18 U.S.C. § 922(g)(1) for possession of a firearm by a felon and moved to suppress the gun as the product of an unlawfully prolonged traffic stop.
- The District Court granted the suppression motion, finding Bradley’s criminal-history questions were off‑mission and that no reasonable suspicion arose during the stop to justify prolongation; the Government appealed only the on‑mission analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bradley’s post‑check questioning about Roberts’ criminal history was within the traffic‑stop “mission” under Rodriguez | Clark: Questions were off‑mission and impermissibly prolonged the stop; evidence should be suppressed | Government: Questions were ordinary inquiries related to verifying authority to drive and thus on‑mission | Court: Questions were off‑mission after the computerized check confirmed registration and authority to drive; prolongation unlawful |
| Whether reasonable suspicion arose during the stop to justify extending it to investigate other crimes | Clark: No reasonable suspicion developed during the mission to warrant further investigation | Government did not appeal this ruling (did not argue reasonable suspicion arose) | Court: No reasonable suspicion arose during the stop to justify prolongation; suppression affirmed |
Key Cases Cited
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic‑stop “mission” limits permissible inquiries; stop cannot be measurably extended absent reasonable suspicion)
- Whren v. United States, 517 U.S. 806 (1996) (traffic stop is a Fourth Amendment seizure; objective reasonableness governs)
- Illinois v. Caballes, 543 U.S. 405 (2005) (a lawful stop can become unreasonable if prolonged beyond its mission)
- United States v. Green, 897 F.3d 173 (3d Cir. 2018) (discusses difficulty of identifying when a stop is measurably extended; assumed mission ended after initial driver exchange here)