D.Neb.: Two cell phones and air freshener not RS; 14 min additional wait for dog unreasonable

There was no reasonable suspicion for a continued detention, and the 14 minute additional wait after defendant was free to leave was unreasonable. United States v. Thompson, 2015 U.S. Dist. LEXIS 20838 (D.Neb. January 13, 2015). As to reasonable suspicion:

The combination of air fresheners, two phones, only one visible bag, referring to military friends to a stranger by rank and last name, clean construction gear, and no hotel reservation do not rise to more “inchoate and unparticularized suspicion or hunch.” See United States v. Guerrero, 374 F.3d 584, 590 (8th Cir. 2004) (“The use of air fresheners shows that [the defendant] either liked the smell of air fresheners or that he was trying to cover up an odor, but that odor need not be the smell of drugs.”).