CA4: Pre-Rodriguez stop was valid under law at time

Rodriguez was decided after the stop, and the circuit recognized de minimus delays in the stop. Moreover, the stop is not calculated merely by time: “Under Digiovanni and other pre-Rodriguez cases, that Deputy McMurray may have been able to end the stop more quickly would not be dispositive. Determining reasonableness involved more than computing the average time it took to perform each required traffic-stop activity and cross-checking this value against a chart.” The stop was reasonable at the time it occurred, and that was good faith. Also, the specific Rodriguez factors weren’t argued, so that’s waived. United States v. Hill, 2017 U.S. App. LEXIS 3264 (4th Cir. Feb. 23, 2017).

The warrantless emergency entry into plaintiff’s home was reasonable. Police had objective information that a person inside had stabbed himself in the chest repeatedly with a steak knife. Oien v. County of San Bernardino, 2017 U.S. App. LEXIS 2961 (9th Cir. Feb. 21, 2017).*

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