The dog sniff of defendant’s car took only five minutes and occurred during the normal incidents of a traffic stop for improper lane change. The officer had watched defendants go into an apartment, retrieve a duffle bag and then followed them and made the stop. There was nearly reasonable suspicion but the court doesn’t even mention it, instead going with the rationale that a dog sniff before identity is confirmed by dispatch is always valid. Williams v. State, 2016 Ga. App. LEXIS 117 (March 3, 2016):
Here, the evidence shows that prior to conducting the open-air sniff, the detective was conducting the ordinary activities of a traffic stop — he approached the F-250, questioned Williams about the traffic violation, and asked for both Williams’ and Espinoza’s identification. See Allen, supra, 298 Ga. at 6-8 (2) (b)-(c). The detective conducted the open-air sniff right after Espinoza produced a fake Georgia ID, and the open-air sniff took only about five minutes to complete. Moreover, at the time of the open-air sniff, the detective was still confirming Williams’ and Espinoza’s identities. Under these circumstances, the open-air sniff did not lengthen the stop. See Allen, supra, 298 Ga. at 5 (2) (a); Rodiguez, supra, 135 S. Ct. at 1618 (II). Consequently, the trial court properly denied Williams’ and Espinoza’s motions to suppress.