NC: Calling for drug dog right away here didn’t extend time, but the sniff became reasonable by RS otherwise developing

The officer here preemptively called for a drug dog before running the DL information on the occupants. That did not measurably extend the time. After calling for the dog, the officer found out there were warrants on one, and then there was an admission of a gun in the vehicle. The totality was reasonable. State v. France, 2021-NCCOA-498, 2021 N.C. App. LEXIS 505 (Sept. 21, 2021) (sort of “no harm, no foul” because the later discoveries cured any other argument).

Defendant’s change of his constitutional argument about his stop and search between the motion to suppress and the appeal is waiver. State v. Johnson, 2021-NCCOA-501, 2021 N.C. App. LEXIS 494 (Sept. 21, 2021).

The affidavit for the search warrant for the house showed probable cause and nexus. State v. May, 2021-NCCOA-514, 2021 N.C. App. LEXIS 493 (Sept. 21, 2021).*

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