State v. DowneyÂ, 251 N.C. App. 829

Deputy Clifton stopped Glenwood Downey for driving left of center and requested license/registration.
While preparing a warning citation, Clifton observed Downey’s shaking hands, rapid breathing, and lack of eye contact.
Officer noted a Black Ice air freshener (which he associated with drug trafficking from training), a prepaid cell phone in the vehicle, and that the BMW was registered to a third party. Downey admitted a prior cocaine conviction and gave vague answers about why he was in the area.
Clifton issued a written warning and returned documents but continued questioning, requested consent to search (denied), then requested a canine sniff (also denied). A K-9 arrived about 14 minutes after the citation was issued and alerted; a subsequent search recovered crack cocaine and drug-related items.
Downey moved to suppress; the trial court initially denied the motion, this Court remanded to determine whether reasonable suspicion arose before the citation was issued, the trial court made new findings and again denied suppression; the Court of Appeals affirmed.

Issue	State's Argument	Downey's Argument	Held
Whether officer had reasonable, articulable suspicion to detain/extend the traffic stop beyond issuance of the warning citation	The combination of nervousness, Black Ice air freshener, prepaid phone, third‑party registration, vague answers about travel, and prior drug conviction gave reasonable suspicion to prolong the stop and conduct a K-9 sniff	These facts are consistent with innocent travel; the tolerable duration ended when the officer communicated he would issue a warning citation, so further detention required reasonable suspicion which was not shown	The court held the six factors, taken together and supported by evidence, gave rise to reasonable suspicion before the traffic stop concluded; denial of suppression affirmed

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (officer may not prolong a traffic stop beyond mission absent reasonable suspicion)
Sokolow v. United States, 490 U.S. 1 (1989) (reasonable‑suspicion inquiry looks to totality of circumstances; innocent behavior may contribute)
Alabama v. White, 496 U.S. 325 (1990) (distinction between reasonable suspicion and probable cause)
State v. Haislip, 362 N.C. 499 (2008) (trial court findings conclusive if supported by competent evidence; conclusions of law reviewed de novo)
State v. Williams, 366 N.C. 110 (2012) (extension of stop requires reasonable articulable suspicion)
State v. Castillo, 787 S.E.2d 48 (N.C. Ct. App.) (reasonable suspicion found from combination of factors including nervousness, masking odors, third‑party registration, prior drug convictions)
State v. Euceda‑Valle, 182 N.C. App. 268 (2007) (reasonable suspicion found where nervousness, air freshener odor, nonregistered vehicle, and evasive travel answers were present)
State v. Reed, 791 S.E.2d 486 (N.C. Ct. App.) (summarizing Rodriguez and limits on prolonging traffic stops)
State v. Bullock, 785 S.E.2d 746 (N.C. Ct. App.) (officer completes mission when communicating citation; further detention requires reasonable suspicion)