State v. Minyoung, 2012 Ohio 411

December 7, 2010, Crime Stoppers tip identified Minyoung as returning to Van Wert from Fort Wayne to sell narcotics.
Tip included Minyoung’s name, vehicle description, license plate, approximate arrival time, and route on U.S. Route 30; tip corroborated by a reliable informant.
Around 10:00 p.m., Trooper Coil stopped the loud-exhaust vehicle and confirmed it matched the tip.
K-9 alerted to drugs; Minyoung and passenger detained; Minyoung removed shoes and disclosed marijuana and later Dilaudid during shoe searches.
Trial court denied suppression; Minyoung indicted July 13, 2011 for possession of drugs; he pleaded no contest May 13, 2011.
Court affirmed denial of suppression and convicted Minyoung; single assignment of error on suppression issue; final judgment affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether continued detention after the traffic stop was lawful	Minyoung: detention beyond traffic stop was unlawful fishing expedition	State: detention lawful pending canine alert and investigation	Denied; detention lawful under investigative stop.

Katz v. United States, 389 U.S. 347 (U.S. Supreme Court 1967) (probable cause and warrant requirements; warrantless searches subject to exceptions)
Delaware v. Prouse, 440 U.S. 648 (U.S. Supreme Court 1979) (vehicle stops require reasonable suspicion for detaining occupants)
State v. Rusnak, 120 Ohio App.3d 24 (6th Dist. 1997) (lawful detention during investigative stop; canine sniff permissible on detained vehicle)
State v. Carlson, 102 Ohio App.3d 585 (9th Dist. 1995) (canine alert during lawful detention justifies search of vehicle)
State v. Williams, 2010-Ohio-3667 (9th Dist. 2010) (dog alert can extend stop; reasonable suspicion)
State v. Kelley, 2011-Ohio-3545 (4th Dist. 2011) (pat-down scope; weapons search; distinction from full search)
Beck v. Ohio, 379 U.S. 89 (U.S. Supreme Court 1964) (totality of circumstances for probable cause; admissibility of evidence)