S.D.Fla.: Collective knowledge requires that the stopping officers have some knowledge of the reason for the stop

Collective knowledge doesn’t apply where the officers making the stop were not informed of what the DEA didn’t communicate. The stop was, however, valid based on traffic violations. The drug dog showed up while the main part of the traffic stop was going on, so Rodriguez wasn’t implicated. United States v. Young, 2016 U.S. Dist. LEXIS 160977 (S.D.Fla. Nov. 8, 2016).

“However, this Court does not view each fact in isolation; rather, we look at the totality of the circumstances to determine if reasonable, articulable suspicion exists. Therefore, considering the totality of the circumstances, including (1) Adan and Tesfaye both acting nervous; (2) they told Officer Edwards conflicting stories about the trip; (3) Tesfaye did not know the name of the passenger they dropped off; (4) the vehicle contained masking agents, a GPS, eye drops, and an energy drink; (5) Tesfaye had recently been put on probation for possession of methamphetamine; and (6) the vehicle was a rental, we conclude there was reasonable and articulable suspicion that Adan and Tesfaye were engaged in criminal activity. And thus, their continued detention [for 45 minutes] until a K-9 unit arrived was lawful.” State v. Adan, 2016 ND 215, 2016 N.D. LEXIS 216 (Nov. 21, 2016).*

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