The dog arrived at defendant’s traffic stop while the information was being entered into the traffic ticket program in the police car’s computer, so the dog sniff did not prolong the stop under the Fourth Amendment. Separately considering the state constitution, the court comes to the same conclusion. Thayer v. State, 2020 Ind. App. LEXIS 161 (Apr. 23, 2020).
Defendants are permitted to issue a Rule 17 subpoena to gather information from NCIC to show that vehicle VIN information was obtained by officers prior to the search warrant. The government argues that they lack standing on that issue, but the court permits them to look to attempt to controvert the search warrant. United States v. Craig, 2020 U.S. Dist. LEXIS 71833 (E.D. Tenn. Apr. 23, 2020).
Defendant’s arrest for a suspected nuisance violation led to find an outstanding warrant for a probation violation. This was attenuation under Strieff. United States v. Chew, 2020 U.S. App. LEXIS 13217 (9th Cir. Apr. 24, 2020).*