CA11: Roadside dog sniff during the records check was reasonable and did not extend the stop

A roadside dog sniff during the records check was reasonable even without reasonable suspicion and did not extend the stop. United States v. Ramirez-Rivera, 2023 U.S. App. LEXIS 10325 (11th Cir. Apr. 27, 2023).

On collective knowledge: “As the surveillance unfolded, Officer Cockerham continued to communicate his observations to responding officers as the facts were developing and before the traffic stop happened. The arresting officers did not rely on a static dispatcher bulletin or ‘round-up packet’ issued by Officer Cockerham based solely on his observation of a concealed firearm.” United States v. Thompson, 2023 U.S. Dist. LEXIS 73263 (E.D. La. Apr. 27, 2023).*

The seizure of defendant’s backpack was unjustified. A search warrant for the backpack led to a search warrant for his residence, and the backpack search is suppressed as is everything that flowed from it. People v. Delerme, 2023 V.I. LEXIS 10 (Super. Ct. Apr. 24, 2023).*

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