\u201c[W]hile waiting for the drug dog to arrive, Morphis placed Gibbs in handcuffs. It’s not clear from this record that that was justified. … But Morphis had reasonable suspicion to extend the stop to wait for the drug dog; and the dog’s alert provided probable cause to search the car. Thus, the car’s contents would have inevitably been discovered by lawful means. Even if Morphis violated the Fourth Amendment in handcuffing Gibbs, suppression of the search’s results is therefore not warranted on that basis. United States v. Sallis, 920 F.3d 577, 582-83 (8th Cir. 2019).\u201d United States v. Gibbs, 2020 U.S. Dist. LEXIS 119381 (E.D. Ark. July 8, 2020).*<\/p>\n\n\n\n
A controlled buy was probable cause for defendant\u2019s stop, and reasonable suspicion wasn\u2019t required. United States v. Cain, 2020 U.S. Dist. LEXIS 119425 (E.D. Ky. May 14, 2020),* adopted, 2020 U.S. Dist. LEXIS 120282 (E.D. Ky. July 8, 2020).* <\/p>\n","protected":false},"excerpt":{"rendered":"
\u201c[W]hile waiting for the drug dog to arrive, Morphis placed Gibbs in handcuffs. It’s not clear from this record that that was justified. … But Morphis had reasonable suspicion to extend the stop to wait for the drug dog; and … Continue reading