State v. John Patrick Linze, Jr., 161 Idaho 605

Officer Bridges stopped a vehicle on Nov. 25, 2013 for a cracked windshield; driver was Mrs. Linze and passenger was John Linze Jr.
Officer Bridges ran warrant checks and began a citation; about nine minutes after the stop he called a deputy K-9 unit.
Deputy Moore and his drug dog arrived ~19 minutes after the stop started; Officer Bridges ceased citation/warrant tasks and provided “cover” while the dog swept the vehicle.
The dog (Hash) alerted after roughly 2.5 minutes of the exterior sweep; officers then searched the vehicle and found a meth pipe; Linze admitted ownership and use.
Linze moved to suppress; the district court denied the motion; the Court of Appeals reversed, and the State sought review by the Idaho Supreme Court.
The Idaho Supreme Court held the brief delay while Officer Bridges assisted the dog sweep impermissibly extended the traffic stop in violation of the Fourth Amendment and vacated the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was unlawfully extended by waiting for the K-9 and conducting a dog sniff	State: Rodriguez allows deviation so long as the total time remains within the objectively reasonable time to complete traffic tasks	Linze: Any abandonment of the stop’s purpose converts the detention into a new seizure and is unlawful absent new reasonable suspicion	Court: Agrees with Linze — abandoning the stop’s purpose (even briefly) impermissibly extended the seizure unless new suspicion arises
Whether conducting the dog sniff itself unlawfully prolonged the stop	State: Dog sniff during the stop is permissible if it does not add time beyond what’s reasonably required to complete traffic-related tasks	Linze: A sniff that requires the officer to stop pursuing traffic tasks adds time and violates Rodriguez	Court: The 2.5-minute period where Officer Bridges ceased traffic tasks to back up the dog added time and was unlawful
Whether the dog’s alert supplied probable cause to search the vehicle	State: Dog alert established probable cause	Linze: Dog unreliable; evidence from search inadmissible because stop was unlawful	Court: Did not reach probable-cause question because the stop was unlawfully extended; suppression required

Delaware v. Prouse, 440 U.S. 648 (stopping a vehicle is a Fourth Amendment seizure)
Illinois v. Caballes, 543 U.S. 405 (dog sniffs during a lawful traffic stop do not automatically implicate Fourth Amendment if they do not prolong the stop)
Rodriguez v. United States, 575 U.S. 348 (traffic stop cannot be prolonged beyond time reasonably required to complete mission to conduct a dog sniff)
United States v. Cortez, 449 U.S. 411 (reasonable suspicion standard for investigative detentions)
State v. Purdum, 147 Idaho 206 (Idaho standard of review for suppression rulings)
State v. Svelmoe, 160 Idaho 327 (recent Idaho suppression precedent cited for review standard)