The officer unreasonably prolonged the stop for the arrival of the drug dog. While subjective intentions aren’t determinative under Whren, here the officer called for the drug dog before the stop even happened. People v. Ayon, 2022 Cal. App. LEXIS 591 (6th Dist. July 6, 2022).
Officers could enter defendants’ curtilage to serve a criminal summons. When they retreated inside, however, the officers could not enter the house to serve a summons for a minor offense. There is no suppression remedy here, however, because no evidence was obtained. State v. Baker, 2022 Tenn. Crim. App. LEXIS 308 (July 5, 2022).
Petitioner gets no CoA for appeal of his Franks IAC claim because it was conclusory. Mullins v. United States, 2022 U.S. App. LEXIS 18546 (6th Cir. July 6, 2022).*