Clayton doctor v. State of Indiana, 57 N.E.3d 846

Detective Simpson (DEA‑task‑force/federally deputized) received CI tips that Doctor concealed cocaine in a black Acura and tracked the car with a court‑authorized GPS.
On June 24, 2014, GPS showed the Acura leaving Atlanta; officers set up surveillance as it returned to Evansville. Detective Simpson observed the Acura had darkly tinted side windows and could not identify occupants.
Officer Fair (marked car) stopped the Acura for a window‑tint violation after it crossed into Evansville; Officer Reed arrived with K‑9 Willy about one minute later.
Officer Reed observed indicators of travel/narcotics and requested consent to search; Doctor refused. Reed deployed K‑9 Willy, who alerted at multiple points and then entered the car and indicated on the passenger floorboard/glovebox.
Based on the K‑9 indications, Detective Simpson obtained a search warrant; officers found a hidden hydraulic compartment in the passenger airbag containing two bags that field‑tested positive for cocaine.
Doctor was charged with dealing in cocaine and conspiracy; he moved to suppress, arguing the stop was pretextual and the stop was unlawfully prolonged. The trial court denied suppression (except for pre‑Miranda custodial statements). Doctor pursued an interlocutory appeal; the appellate court affirmed and denied the State’s motion to dismiss the appeal as untimely.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Doctor)	Held
Timeliness of interlocutory appeal	The appellant failed to timely file a Notice of Appeal, so appeal should be dismissed.	Doctor says a premature Notice was filed on July 6 and a second filing on Sept 30 followed clerk guidance; the motions panel already denied dismissal.	The court found the premature filing was a curable form defect; acceptance of jurisdiction cured it and denial of dismissal is affirmed.
Validity of traffic stop and subsequent search/K‑9 sniff	Stop was supported by reasonable suspicion of a window‑tint violation; K‑9 alerts provided probable cause for search (automobile exception); stop duration (8–12 min) was reasonable.	Stop was pretextual and unreasonably prolonged to allow a K‑9 sniff and to obtain evidence; CIs were uncorroborated.	The court held the officers had reasonable suspicion to stop (could not identify occupants through tinted side window), the stop was not unreasonably prolonged, K‑9 alerts supplied probable cause (warrant not required but was obtained), and suppression was properly denied.

Treacy v. State, 953 N.E.2d 634 (Ind. Ct. App. 2011) (appellate court has inherent authority to revisit motions‑panel rulings while appeal is pending)
Sanders v. State, 989 N.E.2d 332 (Ind. 2013) (officer’s inability to identify occupants through window can supply reasonable suspicion for a tint‑statute stop)
Bush v. State, 925 N.E.2d 787 (Ind. Ct. App. 2010) (traffic stop is a seizure; lawful at inception but may become unlawful if unreasonably prolonged)
Johnson v. State, 992 N.E.2d 955 (Ind. Ct. App. 2013) (legitimate safety and enforcement interests support tint‑statute stops; officers may briefly detain to check license/plate)
State v. Hobbs, 933 N.E.2d 1281 (Ind. 2010) (automobile exception permits warrantless vehicle searches when probable cause exists; K‑9 alerts can establish probable cause)
Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (Article I, §11 reasonableness test balances suspicion, intrusion, and law enforcement needs)