The officer had no reasonable suspicion developed from defendant’s traffic stop. The rental car was a one-way rental in the name of another and defendant had multiple cell phones. The stop, for all intents and purposes, appears strung out to allow time for a drug dog to arrive. The officer repeatedly looked at the rental agreement, but it’s apparent he wasn’t reading it because defendant volunteered that the car was in the name of another and the officer was surprised by that. State v. Salcedo, 2019 Iowa Sup. LEXIS 101 (Nov. 8, 2019).
The testimony about the CI’s information at the suppression hearing satisfied both prongs of Augilar and Spinnelli (still the law in New York). People v Steinmetz, 2019 NY Slip Op 08038, 2019 N.Y. App. Div. LEXIS 8044 (4th Dept. Nov. 8, 2019).*