OH5: Using dog before purpose of stop completed was valid

Running a dog around defendant’s car before the purpose of the traffic stop was even complete was not unreasonable. State v. Latona, 2011 Ohio 1253, 2011 Ohio App. LEXIS 1065 (5th Dist. March 16, 2011):

[*P27] We also find that at the time Trooper Norman walked his dog around Appellant’s vehicle, Trooper Norman had not fulfilled the purpose of the initial stop in that Trooper Norman was waiting for the information to return from the dispatch and he had not cited Appellant for the marked lanes violation. The United States Supreme Court has stated that a dog sniff does not constitute a search. United States v. Place (1982), 462 U.S. 696, 103 S.Ct. 2637, 77 L.Ed.2d 110. Thus, because a dog sniff is not a search, “an officer need not have formed a reasonable suspicion that drug-related activity is occurring in order to request that a drug dog be brought to the scene or to conduct a dog sniff of the vehicle.” Guckert, supra [2000 WL 33226314] citing State v. Keller (Jan. 14, 2000), Montgomery App. No. 17896. Thus, when a motorist is lawfully detained pursuant to a traffic stop and when the purpose of the traffic stop has yet to be fulfilled, the Fourth Amendment is not violated when the officer employs a trained narcotics canine to sniff the vehicle for drugs. Guckert, supra.

[So, in Ohio, it apparently is permissible to use a dog during any traffic stop.]