Criminal history check is a permissible mission-related activity during a traffic stop and the fact the officer conducted it through dispatch instead of computer did not unreasonably extend the duration of the stop.
Defendant (Mayville) challenged the district court’s denials of his motions to suppress evidence of drugs and firearms seized from his car by Utah Highway Patrol troopers during a traffic stop. Mayville argued the troopers violated his Fourth Amendment rights described in Rodriguez v. United States because they unjustifiably prolonged the traffic stop beyond the time needed to complete the tasks incident to the stop’s mission by running a criminal history check through dispatch. The Tenth Circuit affirmed. “This is because reasonableness—rather than efficiency—is the touchstone of the Fourth Amendment.” The Court held the traffic stop did not exceed the time reasonably required to execute tasks relevant to accomplishing the mission of the stop, the nineteen-minute roadside detention did not offend the Fourth Amendment.
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