Defendant’s three sentence motion to suppress said it would follow up with authority. The motion and hearing without that authority narrowed the scope of the claim and abandoned the justification for the stop and any state constitutional claim. What developed during the stop was probable cause on the totality, and the claim the dog sniff was unreasonable is moot. Pier v. State, 2018 WY 79, 2018 Wyo. LEXIS 83 (July 13, 2018).
The DEA asked the MSP to make a stop of defendant, which was for a traffic offense. Defense counsel wasn’t ineffective for not challenging the subsequent search (1) because a drug dog alert that happened while the initial stop was being conducted was reasonable, and (2) because the DEA had probable cause for the search. United States v. Patton, 2018 U.S. Dist. LEXIS 114543 (E.D. Mich. July 10, 2018).*