State v. Fisher, 219 N.C. App. 498

On 9 February 2010, a drug investigator observed Fisher driving without a seatbelt in a high-speed traffic context on Highway 70 West.
The officer followed Fisher for about three miles and observed the vehicle’s tag did not match the vehicle’s registered owner, a third-party concern in drug cases.
A hand print on the trunk suggested something had recently been placed there, indicating potential contraband transport.
The officer noted a strong odor of air freshener and Fisher’s nervous demeanor, both considered suspicious indicators of drug activity.
The stop was for the seatbelt violation; the officer detained Fisher and waited for a canine unit to arrive, during which Fisher allegedly conveyed no consent to search and faced delays.
Emmy, a drug-detection dog, signaled the presence of drugs, leading to a search that recovered two pounds of marijuana in the trunk.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was reasonable suspicion to detain beyond the traffic stop	Fisher argues no reasonable suspicion existed	State contends combined factors created reasonable suspicion	Yes; totality of circumstances supported detention beyond stop.

State v. Cooke, 306 N.C. 132 (1982) (standard of reviewing findings of fact in suppression appeals)
State v. Hughes, 353 N.C. 200 (2000) (conclusion of law reviewed; evidence map governs suppression ruling)
State v. Branch, 162 N.C.App. 707 (2004) (prior knowledge plus present observations can justify further investigation)
State v. Euceda-Valle, 182 N.C.App. 268 (2007) (factors like nervousness, odor, nonregistration support reasonable suspicion for canine sniff)
McClendon v. State, 350 N.C. 630 (1999) (inconsistent statements plus nervousness can establish reasonable suspicion)
Briggs v. State, 140 N.C.App. 484 (2000) (probation status plus red eyes and odor evidence support suspicion)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog alert during routine stop does not alone violate Fourth Amendment)
Sokolow v. United States, 490 U.S. 1 (1989) (totality-of-circumstances test for reasonable suspicion)