Id., at *4. The Supreme Court's ruling in Whren nullifies our previous approach to such Fourth Amendment challenges, see United States v. Robles-Alvarez, 75 F.3d 559, 561 (9th Cir. 1996), of asking whether a reasonable officer under the same circumstances would have made the stop anyway, apart from his or her suspicions about other more serious criminal activities. 1996 WL 305735, at *5-6. [7] Under Whren, Doe is precluded from challenging the traffic stop based on Kidd's subjective intent.