Illinois v. Caballes
United States Supreme Court
543 U.S. 405 (2005)
- Written by DeAnna Swearingen, LLM
Facts
Roy Caballes (defendant) was pulled over for a routine traffic stop by Illinois State Trooper Daniel Gillette. Another trooper, Craig Graham, heard Gillette’s report on the radio and took his narcotics-detection dog to the scene. Graham let his dog sniff the car while Gillette wrote Caballes a warning ticket. The dog detected drugs in the trunk, and the officers conducted a search. They found marijuana and arrested Caballes. This process took ten minutes. At trial, Caballes moved to suppress the evidence and quash his arrest. The trial judge denied the motion, because the stop was not unreasonably prolonged and the dog’s alert gave the officers probable cause to search the trunk. Caballes was convicted, fined $256,136, and sentenced to 12 years in prison. The appellate court upheld the conviction, but the Illinois Supreme Court reversed on the grounds that the sniff test unfairly broadened an ordinary traffic stop and turned it into a drug investigation without “specific and articulable facts” indicating the presence of drugs. The U.S. Supreme Court granted certiorari to address whether the Fourth Amendment prohibits employing a drug dog to perform a sniff test during a routine traffic stop unless the officer has “reasonable, articulable suspicion.”
Rule of Law
Issue
Holding and Reasoning (Stevens, J.)
Dissent (Souter, J.)
Dissent (Ginsburg, J.)
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