In United States v. Taylor, the United States Court of Appeals for the Sixth Circuit considered crucial questions about the limits of police authority during traffic stops, particularly the use of prolonged detention and K-9 units in situations where reasonable suspicion is in question.1 This case centers on a traffic stop conducted by law enforcement that led to the discovery of a firearm—but not without controversy. The court’s decision examines whether law enforcement exceeded constitutional boundaries when detaining Taylor, a felon, beyond the time needed to issue a citation.
On January 21, 2019, Officer Cox of the Knoxville Police Department’s drug interdiction team conducted what began as a routine traffic stop on Interstate 275. Officer Cox, who frequently patrolled the interstate targeting narcotics and criminal activity, pulled over Nathaniel Taylor for driving 69 miles per hour in a 55-mile-per-hour zone. As captured by her dashcam, the interaction began routinely, with Officer Cox informing Taylor of his speed violation and asking for his license and proof of insurance. Taylor explained that he was returning from a job interview and acted cooperatively, though he appeared flustered as he struggled to locate his insurance documentation, moving quickly between the glove compartment and the center console without finding the insurance paperwork. Before heading back to her patrol car, Officer Cox noticed multiple air fresheners on Taylor’s gear shift. She told Taylor he could continue looking for his insurance documents and assured him that if he found them, he could avoid a ticket.
Taylor eventually found the documentation and signaled Officer Cox by waving the paper out of his window. When she returned to his car, Taylor provided proof of insurance, and Officer Cox assured him that he would not receive a ticket for that issue. However, she also told him to stop moving inside his car, even though she acknowledged that he was complying with her initial request. Officer Cox then returned to her vehicle to complete the speeding citation, but before finishing, she requested a K-9 unit. She later explained that her request was based on Taylor’s criminal history, his travel plans, and the presence of air fresheners.
When the K-9 unit arrived, she removed Taylor from his vehicle, conducted a pat-down, and allowed the dog to sniff around the car. The dog alerted to the presence of drugs, prompting a search of the vehicle. No drugs were found, but officers discovered a firearm in the trunk. Taylor, as a convicted felon, was prohibited from possessing a firearm under federal law.
In the aftermath of the encounter, Taylor was indicted for being a felon in possession of a firearm. When the case reached the lower court, the defendant moved to suppress the evidence of the gun, arguing that the officer lacked reasonable suspicion to detain him beyond the time necessary to issue a traffic citation. Unpersuaded, the district court denied Taylor’s motion to suppress.
Taylor conditionally pleaded guilty and appealed to the Sixth Circuit Court of Appeals. The crux of his appeal rested on the court’s review of the denied suppression motion, with the case hinging on whether the prolonged detention violated Taylor’s constitutional rights under the Fourth Amendment.
The Sixth Circuit’s opinion was grounded strictly in precedent. In Whren v. United States, the Supreme Court held that traffic stops are seizures under the Fourth Amendment and, as such, must be reasonable at their start and execution.2 Additionally, the reasonableness of a traffic stop depends on whether the police have reasonable suspicion to believe that a traffic violation has occurred.3 Be aware that a traffic stop that is constitutionally sound at its inception could eventually impinge on the vehicle occupant’s rights in some circumstances. If an officer executes a traffic stop unreasonably, the stop could violate the Fourth Amendment rights of the person seized.4 At a minimum, a lawful traffic stop must be limited in scope and duration. An officer needs reasonable suspicion to prolong a traffic stop beyond what is necessary to resolve the initial reason for the stop.5
When this case reached the Sixth Circuit on appeal, the question for the court was twofold: first, whether Officer Cox had reasonable suspicion to stop Taylor’s vehicle and, if so, whether she had reasonable suspicion to detain him further after she completed the tasks necessary to resolve the initial stop.
The Sixth Circuit reversed the denial of the defendant’s motion to suppress and remanded the case back to the district court.
The appellate court made three key findings. First, the court held that the initial traffic stop was justified based on the facts at hand. Officer Cox had reasonable suspicion to initiate the traffic stop, as the defendant was speeding, driving more than the 55-mile-per-hour speed limit posted on the interstate signs. Second, the court found that Officer Cox did not have the requisite reasonable suspicion to prolong the traffic stop to conduct a dog sniff of the defendant’s vehicle. Officer Cox cited several factors for her suspicion: Taylor’s travel plans, his criminal history, multiple air fresheners in his vehicle, and his movements while searching for insurance. However, the court found these reasons insufficient, tackling each factor one by one. Taylor’s travel route was merely a guess by Officer Cox, with no follow-up questions to confirm inconsistencies. His criminal history, while relevant, couldn’t justify the prolonged stop without stronger indicators of illegal behavior. The air fresheners carried little weight since there was no trace odor of marijuana or any other suspicious smells.
Finally, the court addressed the officer’s concerns regarding Taylor’s movements during the stop. When requesting a K-9 unit, Officer Cox made no mention of Taylor’s movements. She mentioned only Taylor’s travel plans, criminal history, and air fresheners. When Taylor asked why he was being searched, Officer Cox explained that Taylor’s travel plans were confusing to her and that she was informed of his criminal history. The court explained that his movements were made in response to Officer Cox’s request to search for insurance, emphasizing the fact that the defendant did not make any significant movements as the officer approached the vehicle. Notably, when the defendant was instructed “not to make any further movements,” he immediately stopped. This, along with Officer Cox’s failure to contemporaneously mention the movements when she discussed her suspicions with the K-9 officer, decreased the weight of this factor.
Ultimately, the court found that this case lacks any of the stronger indicators of criminal conduct typically necessary to establish reasonable suspicion. The threshold for reasonable suspicion may be low, but it is not nonexistent. As such, the court held that Officer Cox lacked a reasonable, articulable suspicion of criminal activity that justified extending Taylor’s stop to conduct a dog sniff.
Third and finally, the court held that the good faith exception to the exclusionary rule did not apply to the firearm seized during the warrantless search of the defendant’s vehicle.
- United States v. Taylor, No. 23-5344, 2024 U.S. App. LEXIS 29055 (6th Cir. Nov. 15, 2024). ↩︎
- Whren v. United States, 517 U.S. 806, 809–10 (1996). ↩︎
- Heien v. North Carolina, 574 U.S. 54, 60 (2014). ↩︎
- Illinois v. Caballes, 543 U.S. 405, 407 (2005). ↩︎
- United States v. Whitley, 34 F.4th 522, 529 (6th Cir. 2022) (citing Rodriguez v. United States, 575 U.S. 348, 354 (2015)). ↩︎
