Under Rodriguez, “[a]s we have explained, having Barker sit in the patrol car was within ‘[t]he reasonable scope of the initial traffic stop’ itself. … The stop was not extended until the officer conducted a search, but by then, probable cause existed. … With no illegal seizure, there was no illegal search.” United States v. Barker, 2020 U.S. App. LEXIS 16205 (8th Cir. May 21, 2020).
“We conclude that Officer Mikowski abandoned the purpose of the traffic stop when he spoke with Deputy Kindelberger, separately moved and seated Jacobsen and Roest on the curb, and had a casual conversation with Roest in order to facilitate a drug dog sniff unsupported by reasonable suspicion. This Court recently explained that, pursuant to Rodriguez, ‘an abandonment occurs when officers deviate from the purpose of the traffic mission in order to investigate, or engage in safety measures aimed at investigating crimes unrelated to roadway safety for which the officers lack reasonable suspicion.’ State v. Still, 166 Idaho 351, 356, 458 P.3d 220, 225 (Ct. App. 2019).” State v. Jacobsen, 2020 Ida. App. LEXIS 49 (May 20, 2020).