State v. Blackstone, 410 P.3d 354

Around 1:40–2:15 a.m., officers responded to a report of two young white males seen running away carrying bulky pillowcases; no burglary had been reported or witnessed.
Officer Salsbury parked a block from where the suspects were seen and, ~30 minutes later, stopped defendant riding a bicycle toward the patrol car for bicycling without a headlight and because defendant "vaguely" matched the radio description.
During the stop Salsbury checked ID and explained the situation; while talking, defendant repeatedly put his hands into his pockets despite orders to remove them.
After the third reach, Salsbury performed an officer-safety patdown, felt and seized a meth pipe and a butterfly knife; defendant was handcuffed six minutes after the stop began.
Defendant moved to suppress, arguing the traffic stop had been unlawfully extended to investigate burglary without reasonable suspicion; trial court denied the motion, defendant convicted, appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was still ongoing (so officer-safety patdown occurred during a lawful encounter)	Stop remained ongoing; processing (ID and traffic investigation) justified continued detention and patdown	Traffic-processing had ended or should have ended and officer shifted to investigating burglary without reasonable suspicion, so the stop was unlawfully extended	State failed to prove stop was still processing the traffic matter; evidence insufficient to support an implicit finding the traffic stop was ongoing — stop not shown lawful at patdown time; suppression required
Whether officer had reasonable suspicion to extend the stop to investigate burglary	Even if traffic stop had ended, Salsbury had reasonable suspicion based on time, location, "vague" match to description, and perimeter set-up	The description was generic, defendant only vaguely matched, was older than described, was alone and on a bicycle (not carrying pillowcase or fleeing), and no burglary had been reported or witnessed	State failed to show objective reasonable suspicion of burglary under the totality of circumstances; extension not justified

State v. Rodgers/Kirkeby, 347 Or. 610 (limits traffic-stop authority; police may not extend traffic stops to investigate unrelated crimes once traffic-related processing is complete)
State v. Rudder, 347 Or. 14 (officer had reasonable suspicion for burglary where alarm was ringing, proximity to house, furtive behavior, visible bulges, nervousness)
State v. Ehly, 317 Or. 66 (standard of review for suppression rulings; appellate courts bound by trial court fact findings if supported by the record)
State v. Nims, 248 Or.App. 708 (officers may not delay citation/processing as a pretext to investigate unrelated matters)
State v. Dennis, 250 Or.App. 732 (state must prove questioning occurred during an unavoidable lull; inconclusive officer testimony defeats state burden)