N.D.Ohio: Almost immediate dog sniff during stop didn’t prolong it

The officer had an objective basis for the stop, so defendant’s pretext claim fails. The dog sniff occurred almost immediately during the stop and the stop wasn’t prolonged for it. United States v. Martinez, 2019 U.S. Dist. LEXIS 155124 (N.D. Ohio Sept. 11, 2019).

When defendant’s car was stopped, there was reasonable suspicion he’d been involved in a bank robbery. The stop ripened to probable cause. United States v. Lewis, 2019 U.S. App. LEXIS 27394 (4th Cir. Sept. 11, 2019).*

The officer opening defendant’s car door was a search, but he stepped away when he was told the car wasn’t part of the search warrant. Shortly, however, there was a dog sniff of the car, and the dog alerted, and that permitted a search of the car. United States v. Bradley, 2019 U.S. Dist. LEXIS 155001 (W.D. Ky. Sept. 11, 2019).*

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