The exclusionary rule applies to forfeiture actions (One 1958 Plymouth Sedan) despite the state’s argument. The dog sniff occurred during the normal processing part of the stop. “Police may conduct a canine sniff during the time that it takes to issue a traffic citation ‘so long as the duration of the traffic stop is not extended beyond what is reasonably necessary to resolve the issue that led to the stop and issue a traffic citation.’” In re $75,000.00 United States Currency, 2017-Ohio-9158, 2017 Ohio App. LEXIS 5604 (8th Dist. Dec. 21, 2017).
Defendant was searched incident to arrest for driving a vehicle with a tag belonging to another car. Since the officer did not see her attach the tag, a custodial arrest was without probable cause and the search that produced amphetamine should have been suppressed. Weaver v. State, 2017 Fla. App. LEXIS 19338 (Fla. 2d DCA Dec. 20, 2017).*