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.
Topics
Practice areas
Questions Presented
- Whether police unlawfully prolonged a routine traffic stop after completing the investigation of the civil traffic violations without reasonable suspicion of unrelated criminal activity.
- Whether evidence obtained during the prolonged detention, including evidence seized from the vehicle, was subject to suppression as fruit of an unconstitutional seizure.
Holdings
- 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.
- Evidence obtained after the traffic investigation was complete must be suppressed because the defendant's continued detention was unconstitutional.
Key quotations
“The police do not earn "bonus time" to conduct additional investigations by an expeditious performance of the traffic-related investigation.”
“That the defendant exhibited signs of nervousness and evasiveness in the context of an involuntary police encounter cannot, without more, generate reasonable suspicion.”
“Ultimately, by the time the trooper finished discussing with the defendant the broken lights and the window tint, the investigation of the civil traffic violations was complete.”
Factual background
A State police trooper stopped Gabriel Cordero's vehicle for broken tail and brake lights and illegally tinted windows. Before the roadside stop, the trooper had confirmed that the vehicle was properly registered, inspected, and insured, that Cordero's license was valid, and that there were no outstanding warrants. After the traffic-related investigation was complete, the trooper continued questioning Cordero based on his nervousness, allegedly inconsistent travel explanations, connection to Holyoke, and prior convictions, eventually obtaining a canine response, a search of the vehicle, and the seizure of approximately 2,000 bags of suspected heroin from the trunk.
Procedural history
Indictments were returned in the Superior Court Department on May 11, 2015. After a hearing, a Superior Court judge denied the defendant's motion to suppress evidence seized from his vehicle. A single justice allowed an interlocutory appeal, and the Supreme Judicial Court accepted the case for direct appellate review.