United States of America v. Robert Lee Drayton, Jr

Holding: The Eighth Circuit affirmed the district court's denial of the motion to suppress, holding that the traffic stop was supported by reasonable suspicion and the subsequent search was lawful.
Standard: Fourth Amendment reasonable suspicion and probable cause
Vote: Panel Decision
Practical effect: The ruling reinforces that minor driving irregularities like drifting over a fog line can justify a traffic stop and clarifies that dog sniffs are permissible if completed before the stop's administrative tasks are finished.

The Eighth Circuit affirmed the denial of a motion to suppress evidence in a drug trafficking case. The court held that the traffic stop was supported by reasonable suspicion and that the subsequent dog sniff did not unconstitutionally prolong the seizure.

Background

Robert Lee Drayton, Jr. was indicted for possession with intent to distribute a controlled substance and possession of a firearm in furtherance of a drug trafficking crime. Following a conditional guilty plea and denial of his motion to suppress, Drayton appealed the district court’s ruling, arguing the second traffic stop lacked reasonable suspicion, was unconstitutionally prolonged for a dog sniff, and that subsequent evidence was fruit of the poisonous tree.

The court’s reasoning

The court found that Officer Jenatscheck had reasonable suspicion to stop Drayton because hitting the fog line and failing to signal can indicate intoxication or other violations. The court held the dog sniff did not prolong the stop because it was completed before the officer finished processing the driver’s license. The court further determined that collective knowledge among officers provided probable cause for the stop based on Drayton’s suspected drug activities earlier that day.

Touching the fog line or changing lanes without signaling can establish reasonable suspicion that the driver is committing other violations, such as driving while intoxicated, and it may be enough to establish reasonable suspicion of a traffic violation.

United States v. Drayton, 24-2519 (8th Cir. 2026)

What it means going forward

The ruling reinforces that minor driving irregularities like drifting over a fog line can justify a traffic stop and clarifies that dog sniffs are permissible if completed before the stop’s administrative tasks are finished.