State v. Lawler, 2020 Ohio 849

Trooper Prather stopped a westbound Buick after observing a lane change without signaling; driver Schidecker and passenger Lawler were rigid and did not look at the trooper.
Trooper checked identities, learned neither occupant was the registered owner; he returned to his cruiser and requested dispatch contact the owner and requested a drug-detection canine.
Within ~8 minutes the dispatcher advised the owner said Schidecker was not supposed to be driving; Trooper also learned Schidecker’s license was suspended.
Trooper waited in his cruiser ~25 minutes for a K-9 to arrive; the dog sniff occurred ~36 minutes after the stop and alerted; subsequent search yielded heroin, meth, paraphernalia, and a scale.
Lawler was indicted; she moved to suppress arguing the stop was unreasonably prolonged awaiting the canine. The trial court granted suppression and the State appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer had reasonable, articulable suspicion to prolong the traffic stop to await a drug-detection dog	State: Totality (rigid posture, head toss, partly open window, suspended license, unauthorized use, inconsistent travel story, location) justified extending the stop	Lawler: Waiting ~25–36 minutes for a K-9 unreasonably prolonged the stop; officer had time/ability to complete traffic processing earlier	Court: No. The combined facts were weak; officer lacked reasonable suspicion of drug activity and did not diligently investigate the owner/license issues — prolongation unlawful; suppression affirmed
Whether the canine sniff occurred within the time reasonably required to complete the traffic-related tasks	State: Investigation shifted to possible unauthorized use/driving under suspension, so extended detention was justified	Lawler: Sniff occurred after officer sat idle and could have processed citations or otherwise concluded the stop	Court: No. By the time officer knew of unauthorized use/suspended license he had information to process citations but waited; K-9 sniff did not timely advance investigation and therefore extended the stop unlawfully

Whren v. United States, 517 U.S. 806 (1996) (traffic stop constitutionality standard)
Rodriguez v. United States, 575 U.S. 348 (2015) (canine sniff beyond traffic mission requires independent justification)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during lawful stop not a search but stop cannot be unreasonably prolonged)
Brendlin v. California, 551 U.S. 249 (2007) (passengers are seized during traffic stops)
Arizona v. Arvizu, 534 U.S. 266 (2002) (reasonable-suspicion totality-of-the-circumstances standard)
State v. Batchili, 113 Ohio St.3d 403 (2007) (Ohio guidance on traffic-stop duration and extensions)
State v. Burnside, 100 Ohio St.3d 152 (2003) (appellate standard of review for suppression hearings)