FL4: Dog sniff of passenger in car stopped with RS was reasonable

“We address an issue of first impression: the propriety of using a drug dog to sniff the passenger of a vehicle during a traffic stop based on a reasonable and articulable suspicion the passenger possesses drugs, where the sniff itself is not based on a warrant or probable cause. Upon consideration of the lens of the totality of the circumstances in this case and utilization of the analysis applicable to a stop authorized by Terry v. Ohio, 392 U.S. 1 (1968), and its progeny, we conclude the officers did not violate the Fourth Amendment. Thus, we affirm the trial court’s denial of the motion to suppress evidence.” Tedford v. State, 2020 Fla. App. LEXIS 16111 (Fla. 4th DCA Nov. 12, 2020).