State v. Beckman, 305 P.3d 912

Trooper Pickers stopped Kent Beckman for speeding on I-80, verified his license/registration, and issued a warning.
After returning Beckman’s documents and saying “everything checks good,” Pickers asked additional questions about drugs; Beckman refused a vehicle search.
At ~7:21 a.m. Pickers told Beckman he was not free to leave and would have to wait for a canine unit; Pickers also read a modified Miranda warning.
The canine arrived ~7:29 a.m.; the dog alerted and Pickers conducted a warrantless search, discovering cocaine and methamphetamine; Beckman was arrested.
Beckman moved to suppress the evidence as the stop was unreasonably prolonged and the search unlawful; the district court granted the motion and the Supreme Court of Nevada affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Beckman)	Held
Whether the traffic stop was unreasonably prolonged by awaiting a canine	Delay was de minimis and officer acted expeditiously to get a dog	Trooper Pickers unlawfully extended the stop beyond time needed to handle speeding	Stop was unreasonably prolonged; seizure unconstitutional
Whether the subsequent canine sniff/search was permissible	Dog sniff is lawful during a stop and need not be supported by reasonable suspicion if it doesn't extend the stop	The dog sniff was the fruit of an illegal, extended seizure	Dog sniff/search inadmissible because it was enabled by the unconstitutional prolongation
Whether Beckman consented to continued detention or a search	Initial questioning and some cooperative answers showed consent to continued encounter	Any apparent consent ended when Beckman asked to leave and was told he could not	No valid consent to continue detention or to search after 7:21 a.m.
Whether exigent circumstances or other facts provided reasonable suspicion to prolong the stop	Officer pointed to nervousness, handprints on trunk, and other observations to justify suspicion	Those facts, viewed objectively, did not create reasonable suspicion to convert the stop into a drug investigation	No reasonable suspicion existed to justify extending the stop

Whren v. United States, 517 U.S. 806 (car stop reasonable where probable cause of traffic violation exists)
Illinois v. Caballes, 543 U.S. 405 (dog sniff during traffic stop OK only if it does not prolong the stop)
United States v. Place, 462 U.S. 696 (dog sniff is not a Fourth Amendment "search")
Florida v. Jardines, 569 U.S. 1 (physical intrusion onto property for investigative purposes is a search)
Lisenbee v. State, 116 Nev. 1124 (Fourth Amendment seizure reasonableness review; evidence from unconstitutional seizure inadmissible)
Gama v. State, 112 Nev. 833 (dog sniff permissible when it does not extend duration of traffic stop)