United States v. William A. Goodwill, 24 F.4th 612

Detectives stopped William Goodwill for an Illinois window-tint violation and asked him to sit in a squad car while they processed a written warning.
Officer Roseman ran LEADS/Secretary of State checks and began handwriting the warning while asking Goodwill various questions (car, job, child, drugs).
A canine unit was dispatched and arrived before Roseman finished the warning; Goodwill consented multiple times to a dog sniff.
The drug dog alerted and officers found two kilograms of cocaine; Goodwill was indicted for possession with intent to distribute.
Goodwill moved to suppress, arguing the officers unlawfully prolonged the stop with unrelated questioning and that the sniff was without valid consent; the district court denied suppression.
The Seventh Circuit reviewed factual findings for clear error and affirmed the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawfulness of ordering driver into squad car	Roseman lacked reasonable justification; moving him was improper	Moving a driver into squad car is reasonably incidental to stop for officer safety	Officer may lawfully request driver relocate to squad car without particularized suspicion; motive irrelevant
Whether unrelated questioning unlawfully prolonged the stop	Questions unrelated to traffic mission and delayed completion of the warning; canine arrival was orchestrated to prolong stop	Officer was actively and continuously completing the warning while speaking; questions did not measurably extend the stop	District court’s factual finding that the stop was not prolonged was not clearly erroneous; questioning permissible if it does not extend duration
Legality of dog sniff	Sniff occurred without valid consent and after officer completed traffic tasks	A dog sniff during an ongoing traffic stop is permissible without consent if it does not prolong the stop	Because paperwork was still being processed when the dog arrived, the sniff was lawful

Rodriguez v. United States, 575 U.S. 348 (2015) (traffic stop may not be extended beyond mission without reasonable suspicion)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during lawful stop is permissible if it doesn't prolong stop)
Whren v. United States, 517 U.S. 806 (1996) (subjective officer motive does not invalidate objectively reasonable Fourth Amendment conduct)
Pennsylvania v. Mimms, 434 U.S. 106 (1977) (officers may order driver out of vehicle for safety)
United States v. Gholston, 1 F.4th 492 (7th Cir. 2021) (deferential review of factual findings on whether unrelated acts extended traffic stop)
United States v. Lewis, 920 F.3d 483 (7th Cir. 2019) (requests to move into squad car are reasonably incidental to a traffic stop)
United States v. Cole, 21 F.4th 421 (7th Cir. 2021) (traffic stops are seizures requiring reasonable suspicion; limits on duration)