The traffic stop was justified, and the district court was correct in holding what happened during the ticket writing phase didn’t deviate from the primary mission of the stop. There’s no fixed rule on the amount of time it could take. The officer testified it could be as little as seven minutes or as much as an hour. It depends. United States v. Lara, 2023 U.S. App. LEXIS 4888 (10th Cir. Feb. 27, 2023):
This case is shaped as much by the arguments Defendant waives as by the ones he raises. Defendant does not challenge the district court’s finding that Trooper Kirlin had reasonable suspicion to stop him for speeding. Nor does Defendant challenge the district court’s finding that Trooper Kirlin had established reasonable suspicion to detain him further by the time the Trooper exited his vehicle to converse with the K9 officer approximately ten minutes into the stop. Rather, Defendant only contends the stop was unjustifiably extended in violation of the Fourth Amendment.