State v. Karst, 509 P.3d 1148

On Nov. 29, 2017 Sergeant Jeremy Hyle stopped a pickup for minor traffic violations; Karst was a passenger not wearing a seatbelt.
Hyle collected driver information and began returning to his patrol car; en route he radioed dispatch (~19 seconds) to request a drug‑dog unit because the truck came from a suspected drug location and the driver’s name appeared in drug intel.
Hyle ran warrants/queries, learned the driver’s license was suspended and the vehicle uninsured, and began preparing citations.
A K‑9 arrived, alerted on the truck, and officers discovered methamphetamine in a tin on Karst and other drug evidence on her person/jail intake.
Karst moved to suppress; the district court denied suppression of the meth (but suppressed some jail/pocket evidence), the Court of Appeals affirmed, and the Idaho Supreme Court granted review.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Karst)	Held
Whether a 19‑second radio call requesting a K‑9 impermissibly extended the traffic stop	The brief call was de minimis, did not abandon the traffic mission, and did not add time to the stop	The 19‑second detour deviated from the stop’s mission and thus unlawfully prolonged the seizure under Rodriguez	Court reversed: the 19‑second radio request prolonged the stop; evidence suppressed; no de minimis exception
Whether an officer must ‘abandon’ the traffic mission (vs. any deviation that adds time) to violate Rodriguez	A Fourth Amendment violation requires abandonment of the traffic mission; mere deviation is insufficient	Timing is irrelevant; any deviation that adds time to the stop violates Rodriguez absent reasonable suspicion	Court rejected the abandonment requirement from Still; focus is whether the deviation added time — abandonment is not determinative

Rodriguez v. United States, 575 U.S. 348 (Supreme Court: a traffic stop may not be prolonged beyond its mission; a dog sniff unrelated to the mission cannot prolong the stop absent reasonable suspicion)
Illinois v. Caballes, 543 U.S. 405 (Supreme Court: a dog sniff during a traffic stop is permissible if it does not prolong the stop)
State v. Linze, 161 Idaho 605 (Idaho Sup. Ct.: deviation from the traffic mission that adds time violates the Fourth Amendment)
State v. Still, 166 Idaho 351 (Idaho Ct. App.: held a short radio request for a K‑9 did not unlawfully extend the stop — overruled by this decision)
State v. Pylican, 167 Idaho 745 (Idaho Sup. Ct.: distinguished Linze where K‑9 had independent reasonable suspicion)
State v. Hale, 168 Idaho 863 (Idaho Sup. Ct.: certain inquiries about vehicle operation are ordinary, traffic‑related tasks)