Getting one of two occupants out of a car during a stop to separate them was reasonable in any traffic stop. That wasn’t a “detention,” and the dog sniff occurring during that part of the stop was reasonable. United States v. Born, 2017 U.S. Dist. LEXIS 87867 (S.D. Ohio June 8, 2017).
Officers had probable cause to arrest, and defendant consented to search his cell phone for text messages. State v. Goodwin, 2017 Tenn. Crim. App. LEXIS 480 (June 7, 2017).*