FUENTES v. STATE, 2021 OK CR 18

In June 2016 a reliable confidential informant (CI) told Det. Chad Cook that Pedro Fuentes and family were trafficking meth; Cook corroborated via a June 13 domestic-disturbance call where officers observed meth and cash.
Cook obtained a warrant to install an electronic tracking device on Fuentes’ car; the device was installed ~June 20, 2016.
A second CI reported Fuentes would travel out of state to pick up a drug load. The tracker showed a trip to Phoenix; Cook organized surveillance and alerted Oklahoma City officers, providing vehicle details and that the driver was suspected to be Fuentes.
On July 16, 2016 Sgt. John Ricketts observed the vehicle speeding and failing to signal, stopped it, ran checks and wrote a citation, then—after being asked to hold Fuentes—called a K9. The dog alerted and officers found ~4,441 grams of meth in a duffle bag; Fuentes admitted ownership but moved to suppress.
Fuentes argued the stop was unlawfully prolonged and Ricketts lacked independent reasonable suspicion to extend the stop; the trial court denied suppression, convicted Fuentes after a bench trial, and sentenced him to 35 years and a fine. The appeal challenges only the denial of the suppression motion.

Issue	Fuentes' Argument	State's Argument	Held
Whether Sgt. Ricketts lawfully extended a traffic stop to deploy a K9 based on reasonable suspicion	Ricketts lacked personal reasonable suspicion to prolong the stop; he could not rely solely on Detective Cook's investigatory information to detain him beyond the traffic citation	Under the collective-knowledge (fellow-officer) doctrine, Cook’s reasonable suspicion imputed to Ricketts justified extending the stop to conduct a K9 sniff	The court held Cook had reasonable suspicion from CI tips and investigation; that suspicion was vertically imputed to Ricketts, so extending the stop for a K9 was lawful and suppression was properly denied

Adams v. Williams, 407 U.S. 143 (1972) (officer may rely on information from others; personal observation not required for reasonable cause)
Hensley v. Williams, 469 U.S. 221 (1985) (officers may act on information transmitted by other officers without cross‑examining the source)
United States v. Arvizu, 534 U.S. 266 (2002) (reasonableness of suspicion judged under totality of the circumstances)
Holt v. State, 506 P.2d 561 (Okla. Crim. App. 1973) (recognizing fellow-officer rule in Oklahoma)
State v. Iven, 335 P.3d 264 (Okla. Crim. App. 2014) (discussion of the collective-knowledge/fellow-officer doctrine)
Seabolt v. State, 152 P.3d 235 (Okla. Crim. App. 2006) (traffic stop duration must relate to and not exceed purpose of stop)
United States v. Chavez, 534 F.3d 1338 (10th Cir. 2008) (describing collective-knowledge doctrine and its applications)
United States v. Pettit, 785 F.3d 1374 (10th Cir. 2015) (reasonable suspicion standard is not onerous; prosecution must justify detention)