IA: Def’s registration papers weren’t in order; while waiting on a response from dispatch, criminal history led to calling drug dog. This didn’t extend the stop

The officer intended only to give a warning, but it took a while for defendant’s registration to clear a computer check. While waiting, the officer checked defendant’s criminal history finding a significant meth history and then called for a drug dog. Because defendant’s paperwork wasn’t in order for a quick check, the dog did not extend the stop. State v. Britcher, 2021 Iowa App. LEXIS 479 (June 16, 2021).

The CI’s information was not corroborated and it didn’t provide sufficient predictive details to show the CI was reliable. The motion to suppress should have been granted. Williams v. State, 2021 Ga. App. LEXIS 284 (June 16, 2021).

“[T]he alleged factual misrepresentations are immaterial to the issuing judge’s probable cause determination.” The search of defendant’s car parked outside his house searched under the warrant was reasonable. United States v. Powell, 2021 U.S. App. LEXIS 17983 (5th Cir. June 16, 2021).*