State of Minnesota v. Jesse Louis Puttbrese, A15-2092

Trooper Hagen, tipped that a vehicle (possibly a red pickup) might carry narcotics, followed a red Ford F-150 that crossed lane lines and stopped slowly.
As the truck slowed, the front-seat passenger (Puttbrese) made a furtive movement reaching forward; troopers observed him as disheveled, fidgety, with pick marks and dilated pupils.
The driver exhibited extreme nervousness (shaking, visible pulse), gave conflicting stories about their trip, and would not clearly claim responsibility for items in the truck.
Hagen asked the driver for consent to search; she did not definitively consent. Hagen decided to conduct a dog sniff and, because policy required the vehicle be empty for the sniff, repeatedly asked Puttbrese to exit.
Upon opening the passenger door, Hagen saw a knife and a meth pipe in plain view; after physical resistance and a search incident to detention, troopers found 51 grams of methamphetamine on Puttbrese.
Procedural posture: District court denied suppression motion; Puttbrese convicted of possession; appeal challenges expansion of the stop and whether the subsequent searches/sniff were lawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers impermissibly expanded scope/duration of the traffic stop	Puttbrese: re-approach and continued detention based on nervousness and vehicle type were not objectively reasonable and unlawfully extended the stop	State: officer had reasonable, articulable suspicion (furtive movement, signs of drug use, conflicting stories, driver’s extreme nervousness) supporting continued investigation	Court: affirmed—expansion was justified by totality of circumstances and reasonable suspicion
Whether drug-dog sniff and ensuing search were lawful	Puttbrese: dog sniff and request to exit lacked independent reasonable suspicion/probable cause and thus were unlawful	State: sniff and request were tied to reasonable suspicion; plain-view items (knife, pipe) and resistance led to lawful search/seizure	Court: affirmed—dog sniff and subsequent discovery/search were lawful under Terry and state precedents

Terry v. Ohio, 392 U.S. 1 (establishes stop-and-frisk reasonableness framework)
State v. Gauster, 752 N.W.2d 496 (Minn. 2008) (standard for appellate review of suppression rulings)
State v. Lugo, 887 N.W.2d 476 (Minn. 2016) (Terry analysis applied to traffic stops)
State v. Askerooth, 681 N.W.2d 353 (Minn. 2004) (second Terry prong and limits on incremental intrusions)
State v. Flowers, 734 N.W.2d 239 (Minn. 2007) (officers may draw inferences from training/experience)
State v. Wiegand, 645 N.W.2d 125 (Minn. 2002) (dog sniff timing and suspicion requirement)
State v. Martinson, 581 N.W.2d 846 (Minn. 1998) (totality of innocent factors plus officer experience can supply reasonable suspicion)
State v. Smith, 814 N.W.2d 346 (Minn. 2012) (nervousness can contribute to reasonable suspicion when paired with other facts)
State v. Burbach, 706 N.W.2d 484 (Minn. 2005) (nervousness plus an unreliable tip and a minor violation insufficient alone for reasonable suspicion)
State v. Syhavong, 661 N.W.2d 278 (Minn. Ct. App. 2003) (nervousness alone is insufficient; must be coupled with objective facts)