State v. Marcos A. Renteria, 415 P.3d 954

Trooper Sproat stopped Renteria for an improper lane change (failed to signal for five seconds) on I-84.
During the stop Sproat requested ID, registration, and proof of insurance; Renteria provided his license and registration but no insurance card.
While Renteria searched for insurance, Sproat asked routine and drug-related questions, then walked to his patrol car and requested a canine unit from dispatch.
A drug-detection dog arrived, sniffed the vehicle several times, and alerted to the presence of drugs.
Dispatch initially could not confirm Renteria’s information, then later confirmed his license; officers then searched the car without a warrant and found a brick of cocaine in the trunk and drugs on Renteria.
Renteria moved to suppress, arguing the stop was unlawfully extended; the district court denied the motion, he pled guilty conditionally to trafficking, and appealed the suppression ruling.

Issue	Renteria's Argument	State's Argument	Held
Whether officer’s drug-related questions during the traffic stop unlawfully extended the detention	Asking about drugs/weapons without reasonable suspicion unlawfully prolonged the stop	Brief unrelated questions are permissible if they do not measurably extend the stop	Court held questions were permissible because they did not extend the stop
Whether requesting a canine unit before completing dispatch checks unlawfully extended the stop	Calling for a canine before finishing the traffic investigation lengthened detention	Request did not add time because it was made while officer walked to patrol car to continue ordinary duties	Court held the request did not extend the stop
Whether discussing suspicions with the canine officer unlawfully prolonged the stop	Discussing drug suspicion with the canine officer exceeded the original stop purpose and extended detention	Conversation occurred while officer awaited dispatch responses and did not prolong the stop	Court held the discussion did not unlawfully extend the stop
Whether the subsequent warrantless trunk search was unlawful because the stop had ended	The stop was concluded before the search, so the trunk search was an unlawful extension	Multiple dog alerts provided probable cause to search the vehicle and trunk without a warrant	Court held the dog alerts gave probable cause and the trunk search was lawful

State v. Neal, 159 Idaho 919 (Ct. App. 2016) (generalized unrelated questions permissible if they do not measurably extend the stop)
State v. Parkinson, 135 Idaho 357 (Ct. App. 2000) (officer may ask brief questions unrelated to traffic purpose without Fourth Amendment violation when stop is not extended)
Arizona v. Johnson, 555 U.S. 323 (2009) (unrelated inquiries do not convert a stop into an unlawful seizure so long as they do not measurably extend its duration)
Rodriguez v. United States, 575 U.S. 348 (2015) (critical inquiry is whether a dog sniff or other action adds time to a lawful stop)
State v. Yeoumans, 144 Idaho 871 (Ct. App. 2007) (reliable drug-dog alert to vehicle odor establishes probable cause to search)
State v. Linze, 161 Idaho 605 (2016) (dog sniffs that do not add time to the stop can be constitutional when another officer pursues the stop’s original objectives)