Facts
Quarrentin Jawhitney Lynn Holmes entered a conditional guilty plea of an indictment charging him with possession with intent to distribute methamphetamine. In this appeal, he challenges the district court’s order denying his motion to suppress evidence seized during a traffic stop. He contends that questions posed to him by a state trooper during and after the traffic stop were improper from the beginning under the totality of the circumstances because they did not actually relate to a reasonable suspicion and because they unconstitutionally prolonged the stop. The 5th affirmed.
Analysis
The protection of the Fourth Amendment extends to vehicle stops and temporary detainment of a vehicle’s occupants. See Andres. Holmes had a reasonable expectation of privacy in the rental car he was driving. See Byrd. A traffic stop is more analogous to a Terry stop than to a formal arrest.
As with Terry stops, the tolerable duration of police inquiries in the traffic-stop context is determined by the seizure’s mission—to address the traffic violation that warranted the stop and attend to related safety concerns. A traffic stop may last no longer than necessary to address the traffic violation, and constitutional authority for the seizure ends when tasks tied to the traffic infraction are—or reasonably should have been—completed. See Rodriguez.
The Fourth Amendment tolerates certain unrelated investigations that do not lengthen the roadside detention. Crucially, if the officer develops reasonable suspicion of additional criminal activity in the course of the stop and before the initial purpose of the stop has been fulfilled, then the detention may continue until the new reasonable suspicion has been dispelled or confirmed. See Reyes.
Holmes asserts that the district court should not have considered: (1) the trooper’s training and experience; (2) his travels to a drug-trafficking hub (Phoenix) and along a known drug-trafficking corridor (Interstate 40); (3) his nervousness; (4) his use of a rental car rented by a third party; (5) inconsistencies with respect to his travel plans; and (6) his failure to mention a recent drug-trafficking arrest. He asserts that the traffic stop should not have been prolonged while the rental agreement was obtained. These contentions are without merit.
Courts examine the totality of the circumstances in determining if an officer had reasonable suspicion. Facts that appear innocent when viewed in isolation can contribute to reasonable suspicion when viewed collectively. Officers are permitted to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that might well elude an untrained person.
Pertinent to this case, we have stated that travel along known drug corridors is a relevant—even if not dispositive—piece of the reasonable suspicion puzzle. During a traffic stop, officers may also ask for rental documents, run computer checks, and ask about the purpose and itinerary of a driver’s trip. See Brigham. A defendant’s use of a rental car, among other facts, is supportive of an officer’s reasonable suspicion for extending a traffic stop. See Glenn.
Nervous behavior is supportive of a reasonable suspicion. See McKinney. Inconsistent stories, especially when combined with other factors, can give rise to reasonable suspicion. See Pack.
We have carefully reviewed the record and the arguments of the parties and have no difficulty in holding that that the district court did not err in determining that, under the totality of the circumstances, the facts articulated by the trooper justified Holmes’s continued detention. The district court’s judgment is AFFIRMED.
https://www.ca5.uscourts.gov/opinions/unpub/21/21-10959.0.pdf