State v. Espinoza-Barragan, 253 Or. App. 743

At about 2:00 a.m., Deputy Landers stopped a Dodge Durango for two traffic violations on I-5 near Salem.
defendant, who spoke Spanish, was driving with two passengers; initial questioning occurred after the stop.
Landers expanded the encounter by researching the vehicle's papers and asking about travel plans, and called a second officer.
Landers eventually searched the Durango and found methamphetamine and cash; defendant and two passengers were arrested.
Defendant moved to suppress the evidence as the result of an unlawful extension of the stop; the trial court denied the motion.
The appellate court held the extension violated Article I, section 9, and reversed and remanded for suppression of evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonable suspicion to extend stop for drug inquiry	State contends facts supported reasonable suspicion.	Duncan argues no reasonable suspicion to extend beyond traffic stop.	Extension violated Article I, section 9.
Admissibility of evidence after unlawful extension	Evidence remains admissible notwithstanding extension.	All evidence obtained from the extension should be suppressed.	Suppression required; reversed and remanded.

State v. Belt, 325 Or 6 (1997) (reasonable-suspicion standard; totality of circumstances)
State v. Ehly, 317 Or 66 (1993) (specific and articulable facts required)
State v. Mitchele, 240 Or App 86 (2010) (appellate scrutiny of traffic-stop suspicions)
Juarez-Godinez, 135 Or App 591 (1995) (drug-investigation extension of traffic stop insufficient)
Dominguez-Martinez, 321 Or 206 (1995) (noncriminal characteristics do not justify extension)
Berry, 232 Or App 612 (2009) (nervousness alone does not establish suspicion)
Frias, 229 Or App 60 (2009) (evasiveness does not alone create reasonable suspicion)
Kentopp, 251 Or App 527 (2012) (combined factors insufficient for suspicion)