D.Me.: False name justified extending traffic stop for dog sniff

“The dog sniff began roughly 12 minutes and 45 seconds into the traffic stop. At that point, Martin had provided two driver’s licenses that spelled his name differently and had verbally provided a separate birth date that did not match either license. The dog sniff therefore began after reasonable suspicion had developed that Martin was concealing his identity. The dog sniff concluded roughly seven minutes later, while Trooper Darcy was still investigating Martin’s identity. In fact, the dog sniff ended at almost exactly the same moment that Martin admitted to not being ‘Micheal Cohen.’ The dog sniff of the vehicle therefore did not unlawfully prolong the traffic stop, and the vehicle was legitimately within the trooper’s custody as part of a lawful traffic stop at the time of the dog sniff.” United States v. Martin, 2019 U.S. Dist. LEXIS 94863 (D. Me. June 6, 2019).*

Defendant summarily alleges he was an overnight guest but didn’t make a proffer. He wouldn’t have standing, but the court will assume it because it finds probable cause for the search warrant on the merits of the search. There was nexus for the search warrant because there police had information from a CI that defendant had sold from his home before. United States v. Gadson, 2019 U.S. Dist. LEXIS 94435 (E.D. Mich. June 5, 2019),* reconsideration denied, 2019 U.S. Dist. LEXIS 115240 (E.D. Mich. July 11, 2019).*