State v. Allen, 298 Ga. 1

Officer Jackson stopped a vehicle for improper lane changes; driver Patrick Scott and passenger Dorian Allen were detained.
Within ~2½ minutes officer explained the stop, asked for IDs; Scott produced a Georgia license and registration; Allen produced a South Carolina ID but said his address differed from the card.
After ~8 minutes Officer Jackson radioed dispatcher to run GCIC/NCIC checks on both occupants; Scott’s check returned quickly but Allen’s took longer.
While awaiting Allen’s records return, Jackson deployed a drug dog for a free-air sniff; the dog alerted ~11½ minutes into the stop, giving probable cause to search the vehicle and revealing ~9.8 pounds of marijuana.
Trial court granted suppression, Court of Appeals affirmed; Georgia Supreme Court granted certiorari and reversed, holding the passenger records check was part of the stop’s mission and performed with reasonable diligence.

Issue	Plaintiff's Argument (Scott/Allen)	Defendant's Argument (State)	Held
Whether running a records check on a passenger during a traffic stop is part of the stop’s mission	The check was unrelated to the traffic violation and unlawfully prolonged the stop	Passenger ID and records checks further officer safety and are ordinary incident to a stop	Records check of passenger is an ordinary officer-safety measure and may be part of the stop’s mission
Whether the dog sniff unlawfully prolonged the stop	Dog sniff occurred after mission-related tasks were complete, so it unlawfully lengthened the stop	Dog sniff occurred while a mission-related records check was pending, so it did not add time	Dog sniff did not prolong the stop because it was done while awaiting a mission-related records check
Whether the officer acted with reasonable diligence in pursuing mission-related tasks	Deployment of dog and records check were a detour to investigate drugs without reasonable suspicion	Officer completed mission-related actions diligently and the records check took only a few minutes	Officer acted with reasonable diligence; overall ~11½-minute detention before alert was reasonable
Whether suppression of discovered drugs was required	Evidence obtained after an unconstitutional prolongation must be suppressed	Evidence admissible because detention and subsequent search were lawful	Suppression reversed; search valid and conviction-related evidence admissible

Illinois v. Caballes, 543 U.S. 405 (dog sniff during lawful traffic stop does not violate Fourth Amendment when it does not prolong the stop)
Rodriguez v. United States, 135 S. Ct. 1609 (the mission of a traffic stop governs permissible duration; unrelated checks cannot prolong the stop)
Hiibel v. Sixth Judicial Dist. Ct. of Nev., 542 U.S. 177 (officer may request identification during a stop without triggering Fourth Amendment seizure)
Pennsylvania v. Mimms, 434 U.S. 106 (officer safety justifies ordering driver out of vehicle)
Maryland v. Wilson, 519 U.S. 408 (officer safety justifies ordering passengers out of vehicle)
Brendlin v. California, 551 U.S. 249 (passengers are seized during a traffic stop)
Whren v. United States, 517 U.S. 806 (subjective intent of officer irrelevant to Fourth Amendment analysis)
United States v. Sharpe, 470 U.S. 675 (reasonableness of detention includes assessment of officer diligence)
Rodriguez v. State, 295 Ga. 362 (Georgia case recognizing identity checks and warrant inquiries as officer-safety measures incident to stop)