D.Nev.: Prior drug arrest, nervousness and driving from CA to MN not reasonable suspicion

“The government argues that three articulable factors support a finding that Detective Schaffner had reasonable suspicion to prolong the stop. First, the government points to the fact that Garcia’s records check revealed two narcotics-related arrests in the past year. Second, the government argues that Garcia had an unusually nervous demeanor throughout his encounter with Detective Schaffner. Third, the government notes that Garcia was traveling from Minnesota, a known drug ‘user’ state, to California, a known drug ‘source’ state. Analyzing these factors in combination and considering the totality of the circumstances of this case, the Court finds that they do not constitute reasonable suspicion for continuing to detain Garcia and Machacek.” United States v. $32,750 in United States Currency, 2016 U.S. Dist. LEXIS 98768 (D.Nev. July 28, 2016).