CA11: Luggage dog alerts to on interstate bus is subject to automobile exception

Defendant was apparently a regular passenger on El Expreso bus traveling from Florida to Texas and back. Intel briefings told him that heroin was being concealed in large cans of food. Defendant had a large can of food in his luggage, and he got a pass and was let go. Two weeks later he was encountered again, and his luggage underneath caused a dog to alert. The officer validly searched the bag under the automobile exception which applied to an interstate bus. Defendant refused to consent to opening a large can of jalapeno peppers, so the officer opened it and found heroin in a container inside. The search was valid. United States v. Pina, 2016 U.S. App. LEXIS 7300 (11th Cir. April 22, 2016).

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