State v. Adan, 886 N.W.2d 841

Officer Clark observed a maroon rental car in Stark County exhibiting what he found suspicious (weaving, driver rigid at "10 and 2," reaching to backseat, avoiding eye contact) but saw no traffic violation and relayed his observations to Officer Edwards.
Officer Edwards later observed the same vehicle in Burleigh County committing traffic infractions (speeding, following too closely) and initiated a lawful stop; he identified driver Adan and passenger Tesfaye.
During the stop Edwards noted nervous behavior by both occupants, conflicting stories about travel/destination, lack of visible luggage, and items in the car (air freshener and aerosol, GPS, eye drops, energy drink); records check revealed Tesfaye was on probation for meth possession.
Edwards issued Adan a warning for the traffic offenses, then asked to continue questioning and requested consent to search; Adan refused, so Edwards called for a K-9 unit.
After a 45-minute wait the K-9 alerted and officers searched the vehicle, seizing over two pounds of marijuana; defendants moved to suppress the evidence, arguing the post-warning detention lacked reasonable suspicion.
The district court denied suppression; the Supreme Court of North Dakota affirmed, holding the totality of factors created reasonable articulable suspicion to extend the stop until the K-9 arrived.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether continued detention after issuance of a traffic warning was supported by reasonable articulable suspicion	The State: officers had reasonable suspicion based on Clark’s observations relayed to Edwards, occupants’ nervousness, inconsistent travel accounts, items in car, Tesfaye’s probation, and rental status	Adan/Tesfaye: post-warning detention lacked reasonable suspicion; the cited facts are innocuous and cannot justify prolonging the stop	Held: Affirmed — under the totality of circumstances those factors together supplied reasonable, articulable suspicion to detain until K-9 arrived
Whether evidence discovered after the extended detention should be suppressed	The State: seizure and subsequent search were lawful because the continued detention was supported by reasonable suspicion	Adan/Tesfaye: evidence tainted by unconstitutional prolongation of stop must be suppressed	Held: Denial of suppression affirmed; evidence admissible

Whren v. United States, 517 U.S. 806 (1996) (officer’s subjective intent does not invalidate a traffic stop based on objective traffic violation)
Rodriguez v. United States, 575 U.S. _ (2015) (a traffic stop cannot be prolonged beyond mission absent reasonable suspicion; dog sniff is not part of traffic mission)
State v. Fields, 2003 ND 81 (N.D. 2003) (reasonableness of investigatory detention judged by totality of circumstances; continued detention needs independent reasonable suspicion)
State v. Kenner, 1997 ND 1 (N.D. 1997) (reasonable-suspicion analysis considers inferences an officer may draw and may include information conveyed by other officers)
State v. Franzen, 2010 ND 244 (N.D. 2010) (presence of odor-masking agents and other items can be a relevant factor in reasonable-suspicion calculus)
State v. Deviley, 2011 ND 182 (N.D. 2011) (multiple innocuous factors may be considered together in determining reasonable suspicion)