Dale Dewayne Fisher v. State, 2015 Tex. App. LEXIS 12472

Deputy Thompson stopped Fisher for a defective license-plate light; Fisher lacked a physical driver's license but gave identifying information.
After a records check showed no warrants and valid registration, Thompson asked Fisher to exit and questioned him again; Thompson smelled burnt marijuana and observed Fisher sweating heavily in cold weather.
Thompson also questioned passenger Bradley, who gave a different departure time from Fisher; Thompson knew both men had lengthy criminal histories and that Highway 259 is a major drug corridor.
Thompson retrieved his drug dog, conducted an open-air sniff, and the dog alerted at the driver’s window and center console.
A subsequent search of the console revealed a pistol, suspected counterfeit currency, and methamphetamine; Fisher was arrested and charged with possession with intent to deliver.
Fisher moved to suppress, arguing the stop was prolonged beyond its purpose; the trial court denied the motion and the conviction (75 years, $10,000 fine) was affirmed on appeal.

Issue	Fisher's Argument	State's Argument	Held
Whether detention/search were unlawfully prolonged after traffic tasks completed	Detention continued without reasonable suspicion once license/registration/warrant checks were done, so subsequent dog sniff/search were unconstitutional	Continued questioning about travel and passenger was related to traffic safety; officers developed reasonable suspicion (odor, sweating, inconsistent statements, criminal histories) before unrelated actions completed	Court held detention and dog sniff were lawful: questioning was related to the stop, reasonable suspicion arose before stop’s mission ended, dog alert supplied probable cause for search

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (dog sniff after completion of traffic tasks unconstitutionally prolonged stop)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during a lawful traffic stop that does not extend its duration does not violate Fourth Amendment)
Muehler v. Mena, 544 U.S. 93 (2005) (officers may ask questions and request identification during a detention even without individualized suspicion)
United States v. Brigham, 382 F.3d 500 (5th Cir. 2004) (questions about origin/destination can be related to traffic-stop objectives)
United States v. Pack, 612 F.3d 341 (5th Cir. 2010) (reasonable suspicion may be based on facts suggesting "something illegal was afoot")
United States v. Sharpe, 470 U.S. 675 (1985) (no rigid time limit on investigatory stops; assess diligence and reasonableness)
Young v. State, 420 S.W.3d 139 (Tex. App.—Texarkana 2012) (standards for review of suppression rulings and assessing traffic-stop detention scope)