D.Neb.: Dog sniff during investigation of a traffic accident didn’t extend the stop

“The evidence before the Court indicates the canine sniff in this case did not prolong the ‘mission’ of Officer Sautter’s traffic accident investigation. The total length of time from when Defendant’s vehicle was struck to when Officer Sautter’s canine alerted was approximately 14 minutes. While the relatively short length of time alone does not automatically mean Defendant’s detention was reasonable, it certainly suggests that the canine sniff did not measurably extend the traffic accident investigation.” United States v. Ruel, 2022 U.S. Dist. LEXIS 48134 (D.Neb. Feb. 14, 2022).

Defendant’s encounter with an off-duty officer was not an investigative detention. State v. Keister, 2022-Ohio-856, 2022 Ohio App. LEXIS 762 (2d Dist. Mar. 18, 2022).*

Defendant was in flight from the police at the time he discarded evidence. There was probable cause to arrest before his flight. People v. Penn, 2022 VI SUPER 17U, 2022 V.I. LEXIS 19 (Feb. 10, 2022).*