Partlow v. State, 199 Md. App. 624

Tavon Partlow was charged with possession of cocaine and possession with intent to distribute; the State nol prossed the mere possession charge after trial.
Partlow moved to suppress cocaine evidence recovered from his person during a traffic stop in Harford County, which the suppression court denied.
Police stopped Partlow after a tip about a drug transaction referenced a tan Cadillac with a specific tag; stop proceeded for alleged stop-sign and brake-light violations.
During the stop, a K-9 alerted to drugs after which police recovered cocaine from Partlow’s underwear; he was arrested and Mirandized.
The trial court found the stop valid, the detention reasonable, and the subsequent searches (including a brief reach/strip-like search) permissible; Partlow was convicted as charged.
On appeal, the Maryland Court of Special Appeals affirmed, addressing challenges to the stop, the delay before the canine alert, and the strip/reach search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the suppression court correct about the stop’s legality?	Partlow (Partlow) argues the stop was pretextual and lacked reasonable suspicion.	State contends the stop had legitimate basis for a traffic violation and, combined with prior knowledge, supported detention.	Yes; the stop and detention were supported by reasonable suspicion and the initial traffic violations.
Was the detention length between the stop and canine alert unreasonably extended?	Partlow asserts the delay violated Fourth Amendment limits for a traffic stop.	State contends the detainment was permissible to allow the K-9 search given the totality of circumstances.	No; the detention duration was reasonable and the dog’s alert occurred within a permissible time frame.
Was the search of Partlow’s person (strip/reach-type) incident to arrest constitutional?	Partlow claims the search was an unlawful public strip search.	State argues the search was within Bell v. Wolfish factors and justified by probable cause after the dog alert.	Yes; the search was reasonable under Bell’s balancing factors given the circumstances.

Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable suspicion-based stop and frisk standard)
Arizona v. Johnson, 555 U.S. 323 (2009) (explicit conditions for Terry stop to proceed from stop to frisk)
United States v. Arvizu, 534 U.S. 266 (2002) (totality of circumstances approach to reasonable suspicion)
Whren v. United States, 517 U.S. 806 (1996) (police may rely on traffic violations to justify stops even if motive is narcotics investigation)
Ofori v. State, 170 Md.App. 211 (2006) (limits on prolonged stops pending K-9; reasonableness of detention duration)
Pryor v. State, 122 Md.App. 671 (1998) (time limits for completing a traffic-stop citation during ongoing investigation)
Paulino v. State, 399 Md. 341 (2007) (define strip search vs. reach-in and reasonableness of searches in public)
Bell v. Wolfish, 441 U.S. 520 (1979) (balancing test for the reasonableness of searches incident to arrest)
Nieves v. State, 383 Md. 573 (2004) (definition of strip search in Maryland context)
Carter v. State, 143 Md.App. 670 (2002) (drug-detection dog use and independent detentions during traffic stops)