Carl W. McNeil v. State, A21A1600

Sergeant stopped a sedan for following too closely; occupants were a female driver and passenger Carl McNeil.
Officer checked licenses, ran warrants, reviewed the rental agreement, and engaged in questioning; these tasks took about 6–8 minutes.
After license/warrant checks were complete and no issues were found, rather than issuing a written warning, the sergeant diverted to extensive questioning about the driver’s candle-making business and asked to see candle wax; the driver consented to a vehicle search.
About ten minutes into the stop, the sergeant ordered McNeil out, saw him reach down, conducted a pat-down, felt a bulge, handcuffed him, and seized a bag that contained heroin; cocaine was later found in his shoe.
McNeil was indicted for drug offenses and moved to suppress, arguing the stop was impermissibly prolonged and the pat-down lacked reasonable belief he was armed; the trial court denied suppression.
The Court of Appeals reversed, holding the sergeant unreasonably prolonged the stop, lacked reasonable articulable suspicion for a continued detention, and the seized drugs were the fruit of the unlawful detention; the court did not reach the separate pat-down constitutionality claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was impermissibly prolonged without reasonable suspicion	McNeil: Officer completed traffic-related tasks and then unlawfully extended the stop to question them about candles, without reasonable suspicion of other criminal activity	State: Continued questioning and investigation about candles and inconsistent statements gave reasonable articulable suspicion to prolong detention	Stop was unlawfully prolonged; no reasonable articulable suspicion justified continued detention, so evidence from the extended detention must be suppressed
Whether the pat-down was lawful because officer reasonably believed McNeil was armed and dangerous	McNeil: Pat-down flowed from unlawful prolonged detention and is inadmissible; alternatively, officer lacked reasonable belief McNeil was armed	State: Officer feared McNeil was armed due to nervousness, rummaging, reaching, criminal history, and suspicion of drug trafficking via candles	Court did not decide this issue after ruling the detention was unlawful; suppression directed on that basis

Rodriguez v. United States, 575 U.S. 348 (2015) (a traffic stop’s mission is limited to addressing the traffic violation and related safety; it cannot be prolonged beyond that mission)
Illinois v. Caballes, 543 U.S. 405 (2005) (a lawful traffic stop may not be expanded in a way that unreasonably infringes Fourth Amendment interests)
State v. Allen, 298 Ga. 1 (2015) (Georgia Supreme Court explaining that unrelated activities must not extend the stop beyond its mission)
Caffee v. State, 303 Ga. 557 (2018) (appellate review may consider uncontradicted video evidence when evaluating suppression rulings)
Flores v. State, 347 Ga. App. 174 (2018) (whether a traffic stop was unreasonably prolonged is often fact-intensive but reviewed de novo)
Weaver v. State, 357 Ga. App. 488 (2020) (continued detention after completion of traffic-stop tasks can be unreasonable and require suppression)