State v. Cash, 483 P.3d 1047

Officer Caitlin Demarest stopped a white van after seeing no registration decal and (mistakenly) believing the plate did not match the vehicle.
While the driver, Aaron Cash, searched for documents, Demarest shone her flashlight into the rear and observed a partially opened flat safe on the floorboard with a purple Crown Royal felt bag and a small clear plastic baggie protruding.
Based on prior experience that Crown Royal bags often contained drug paraphernalia, Demarest asked Cash to open the safe; she then saw orange hypodermic needle caps and Cash exclaimed there was a meth pipe in the safe.
Demarest called for backup, discovered an outstanding warrant for Cash, arrested him, and the subsequent search of the van yielded methamphetamine, diazepam, and paraphernalia.
Cash moved to suppress, arguing the traffic stop was unlawfully extended into a drug investigation; the district court denied suppression, a majority of the Court of Appeals affirmed, and the Kansas Supreme Court granted review and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable suspicion to extend a traffic stop after seeing a Crown Royal bag and a plastic baggie protruding from a safe	The State: the items, viewed together and in light of the officer's training/experience, furnished a particularized, objective basis to suspect drug activity and justify extending the stop	Cash: those ordinary items and the safe have innocent uses; they do not provide the particularized, objective facts required to extend a stop	Held: The totality of circumstances (partially opened safe, Crown Royal bag, baggie, officer experience) gave rise to the minimum objective justification for reasonable suspicion to extend the stop
Whether the Court of Appeals applied the correct objective totality-of-the-circumstances standard	The State: the panel evaluated whether Demarest's subjective suspicion was objectively reasonable using the totality-of-the-circumstances test	Cash: the panel failed to apply an objective test and relied improperly on officer's subjective belief	Held: The panel properly applied the objective totality-of-the-circumstances standard and its conclusion was affirmed

State v. Jones, 300 Kan. 630 (examined limits on extending a stop; requires particularized, objective basis for suspicion)
State v. Schooler, 308 Kan. 333 (describes officer's mission during a traffic stop and limits on inquiries that extend duration)
Rodriguez v. United States, 575 U.S. 348 (authority for a stop ends when tasks tied to the stop are completed)
Terry v. Ohio, 392 U.S. 1 (established investigative-detention/reasonable suspicion framework)
Whren v. United States, 517 U.S. 806 (subjective officer motivation is irrelevant; objective standard controls)
United States v. Arvizu, 534 U.S. 266 (totality-of-the-circumstances allows officers to draw on training and experience)
State v. Jimenez, 308 Kan. 315 (officer may broaden inquiry when reasonable suspicion of separate criminal activity arises)
State v. DeMarco, 263 Kan. 727 (State must show a particularized and objective basis for suspecting criminal activity)