Defendant’s argument that the police must show only that they had a motive to investigate a traffic offense and not any criminal offenses that they already know about is foreclosed by Whren. A mixed motive is not unconstitutional. United States v. Beachem, 2018 U.S. Dist. LEXIS 178858 (N.D. Ind. Oct. 18, 2018).
Based on a collection of factors, the officer had probable cause for an automobile exception search at the time he sought a search warrant for the car and before a dog sniff. Therefore, the dog sniff is irrelevant. United States v. Wright, 2018 U.S. Dist. LEXIS 178176 (W.D. Va. Oct. 17, 2018).*