{"id":21156,"date":"2016-03-06T11:35:02","date_gmt":"2016-03-06T16:35:02","guid":{"rendered":"http:\/\/fourthamendment.com\/?p=21156"},"modified":"2016-03-06T11:39:12","modified_gmt":"2016-03-06T16:39:12","slug":"ga-holds-that-a-dog-sniff-before-dispatch-confirms-id-is-valid-because-it-didnt-extend-the-stop","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=21156","title":{"rendered":"GA holds that a dog sniff of a car before dispatch confirms ID is valid because it didn’t extend the traffic stop"},"content":{"rendered":"

The dog sniff of defendant\u2019s car took only five minutes and occurred during the normal incidents of a traffic stop for improper lane change. The officer had watched defendants go into an apartment, retrieve a duffle bag and then followed them and made the stop. There was nearly reasonable suspicion but the court doesn\u2019t even mention it, instead going with the rationale that a dog sniff before identity is confirmed by dispatch is always valid. Williams v. State<\/a>, 2016 Ga. App. LEXIS 117 (March 3, 2016):
\n<\/p>\n

Here, the evidence shows that prior to conducting the open-air sniff, the detective was conducting the ordinary activities of a traffic stop \u2014 he approached the F-250, questioned Williams about the traffic violation, and asked for both Williams’ and Espinoza’s identification. See Allen, supra, 298 Ga. at 6-8 (2) (b)-(c). The detective conducted the open-air sniff right after Espinoza produced a fake Georgia ID, and the open-air sniff took only about five minutes to complete. Moreover, at the time of the open-air sniff, the detective was still confirming Williams’ and Espinoza’s identities. Under these circumstances, the open-air sniff did not lengthen the stop. See Allen, supra, 298 Ga. at 5 (2) (a); Rodiguez, supra, 135 S. Ct. at 1618 (II). Consequently, the trial court properly denied Williams’ and Espinoza’s motions to suppress.<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"

The dog sniff of defendant\u2019s car took only five minutes and occurred during the normal incidents of a traffic stop for improper lane change. The officer had watched defendants go into an apartment, retrieve a duffle bag and then followed … Continue reading →<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[27],"tags":[],"class_list":["post-21156","post","type-post","status-publish","format-standard","hentry","category-dog-sniff"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/21156","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=21156"}],"version-history":[{"count":3,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/21156\/revisions"}],"predecessor-version":[{"id":21159,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/21156\/revisions\/21159"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=21156"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=21156"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=21156"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}