State v. Gibson, 2015 Ohio 3812

Trooper Laubacher stopped Almon Gibson on I-75 for speeding; Gibson produced a Michigan temporary license and a rental agreement showing he was not an authorized driver.
Laubacher, trained in drug interdiction, noted indicators he associates with drug couriers: travel from Detroit (a known distribution center) to a southern user city, rental car not listing driver, nervous behavior, and inconsistent answers about travel and license history.
After issuing a warning, Laubacher asked to search the vehicle; Gibson refused. Laubacher then requested a narcotics-detection canine; Gibson was detained in the cruiser while the canine was en route.
Twenty-four minutes later the canine arrived, alerted on the vehicle exterior, and a search uncovered 27 forged credit cards. Gibson moved to suppress the cards as the product of an unlawful extended detention.
The trial court denied suppression, finding Laubacher had specific and articulable facts giving rise to reasonable suspicion to extend the stop; Gibson pleaded no contest, was convicted and sentenced, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was unlawfully extended to wait for a drug dog	State: Laubacher’s observations and training produced reasonable suspicion to prolong the stop	Gibson: No reasonable suspicion existed; extension for dog sniff violated Rodriguez	Court: Totality of circumstances gave reasonable suspicion; extension lawful
Whether officer failed to diligently pursue means to quickly confirm or dispel suspicion during the 24‑minute detention	State: Officer ran computer checks and questioned Gibson; consent to search was denied, leaving dog as reasonable next step	Gibson: Officer could have pursued other steps or searched earlier, making detention unreasonably long	Court: Officer diligently pursued available investigative steps; detention was not unreasonably long

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic stop may not be prolonged for a dog sniff absent independent reasonable suspicion)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during a lawful traffic stop does not by itself implicate the Fourth Amendment)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion can arise from a series of innocent acts viewed together)
United States v. Arvizu, 534 U.S. 266 (2002) (officers may rely on training and experience to draw inferences supporting reasonable suspicion)
United States v. Sharpe, 470 U.S. 675 (1985) (duration of detention assessed by whether police diligently pursued means of investigation likely to confirm or dispel suspicion)
State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of appellate review for suppression rulings)
State v. Mays, 119 Ohio St.3d 406 (2008) (traffic stop justified by observed speeding)