MI: Video showed the stop was extended without RS

Defendant’s seizure after a traffic stop was without reasonable suspicion under Rodriguez. “We have reviewed the relevant testimony as well as the complete video/audio recording of the encounter from Daniels’s first observation of defendant’s car through the arrest. On the basis of this review, we have concluded that Daniels did not have a reasonable suspicion of any criminal activity sufficient to justify his extension of the traffic stop to allow for a dog sniff. Daniels’s stated justifications were either not consistent with the videotape record or were not sufficient to create a reasonable suspicion of criminal activity.” People v. Kavanaugh, 2017 Mich. App. LEXIS 1090 (July 6, 2017).

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