Eighth Circuit: United States v. Brent Englehart

Fourth Amendment

When a police officer has a conversation that is at least partially consensual with a person asked to sit in the patrol car while a traffic citation is being written, if the person admits possession of contraband in he first three minutes after the ticket is written, the intrusion is de minimis.

http://media.ca8.uscourts.gov/opndir/16/01/152343P.pdf