CA5: Some things were innocent in isolation, but they were RS on the totality

Some factors were innocent on their own, but the totality there was reasonable suspicion. United States v. Goodin, 2021 U.S. App. LEXIS 3881 (5th Cir. Feb. 10, 2021)*:

Goodin’s arguments are unconvincing. First, as the trial court found, while some of these factors may be susceptible to innocent explanations, the combination of factors amounted to reasonable suspicion. Second, asking about Goodin’s criminal history is a lawful component of a traffic stop that protects officer safety. See Rodriguez, 575 U.S. at 356, 135 S. Ct. 1609, 1616-17. Third, the officer’s suspicion about the Louisiana ID was not just related to Goodin’s living out of state, it was also that Goodin’s height did not match the height on the proffered (but fraudulent) ID. Third, there is no blanket rule that officers, when pressed for time while calling in support, need to articulate all of the reasons they are asking for that support or a drug dog.

Therefore, the officer had reasonable suspicion to detain Goodin pending the arrival of a drug dog, and the motion to suppress was properly denied.

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