Commonwealth v. Cordero

Summary

The Massachusetts Supreme Judicial Court held that police may not prolong a routine traffic stop to investigate unrelated criminal activity once the traffic-related tasks are complete, absent reasonable suspicion. Nervousness, evasive answers, travel from a purported drug-source city, and prior convictions, considered on the facts presented, did not establish reasonable suspicion. The court reversed the order denying the defendant's motion to suppress evidence seized from the vehicle.

Holdings

1. Once an officer has completed the investigation of the civil traffic violations, the officer must allow the motorist to leave unless specific and articulable facts give rise to reasonable suspicion of additional criminal activity.
2. Evidence obtained after the traffic investigation was complete must be suppressed because the defendant's continued detention was unconstitutional.

Questions Presented

1. Whether police unlawfully prolonged a routine traffic stop after completing the investigation of the civil traffic violations without reasonable suspicion of unrelated criminal activity.
2. Whether evidence obtained during the prolonged detention, including evidence seized from the vehicle, was subject to suppression as fruit of an unconstitutional seizure.

Disposition

reversed