Suppression of a firearm in the criminal court was not collateral estoppel to a civil case for false arrest, particularly where plaintiff offered no evidence at all. Davidson v. City of New York, 2017 NY Slip Op 08313, 2017 N.Y. App. Div. LEXIS 8391 (1st Dept. Nov. 28, 2017).
There is no bright line rule for what’s too much time under Rodriguez. Here, reasonable suspicion was developing. United States v. Gomez-Hernandez, 2016 U.S. Dist. LEXIS 192069 (D. N.M. June 13, 2016).
Defendant’s truck was stopped at an immigration checkpoint, and the bill of lading had white-out and handwriting on it, which is unusual for a bona fide commercial load and common for drug couriers. That, coupled with defendant’s shaking hands when he handed it over, was reasonable suspicion and the dog sniff was valid. United States v. Escobar, 2017 U.S. Dist. LEXIS 194838 (S.D. Tex. Nov. 28, 2017).*