State v. Navarro, 400 P.3d 1120

Late-night police surveillance on a St. George tire shop observed Navarro leave in an SUV with darkly tinted windows and a visible rifle case in the rear hatch. Officer Parry believed Navarro was a felon and possibly armed.
Officers stopped Navarro’s SUV for a suspected illegal window tint; another car in the convoy was also stopped and briefly diverted officer attention.
Navarro told officers he had a knife on his belt and a firearm in the vehicle; officers frisked and handcuffed him for safety. No on-scene tint meter was available initially.
Parry, who had independent recollection of Navarro’s prior felony plea, came to the scene; an officer later ran a computer check and found Navarro was not a felon.
While waiting for the tint meter, Parry called a drug dog. The dog alerted on the SUV and officers searched it, finding two firearms, drug paraphernalia, and a substance alleged to be methamphetamine.
Navarro moved to suppress the evidence as the product of an unlawful extension of the traffic stop; the trial court denied suppression and the appellate court affirmed.

Issue	Navarro's Argument	State's Argument	Held
Whether police unreasonably expanded a lawful traffic stop into a narcotics/weapon investigation	Stop was a pretext for a drug investigation; officers did not promptly pursue measures to conclude the tint stop, so the detention exceeded scope and time permitted under Lopez	Officers had independent reasonable suspicion of a weapons offense (Parry’s memory of felony plea + visible rifle case); a drug dog alerted before tint meter arrived; the stop and brief extension were reasonable	Court held detention and search were reasonable: Parry’s independent reasonable suspicion justified investigation for weapons; the timeline (≈27 minutes) and totality of circumstances made the delay permissible; dog alert provided grounds to search

Ohio v. Robinette, 519 U.S. 33 (U.S.) (Fourth Amendment reasonableness assessed by totality of circumstances)
United States v. Sharpe, 470 U.S. 675 (U.S.) (appellate courts must avoid post hoc second-guessing of police tactics when detention is reasonable)
State v. Lopez, 873 P.2d 1127 (Utah 1994) (length and scope of detention must be tied to circumstances that justified stop)
State v. Baker, 229 P.3d 650 (Utah 2010) (officer may investigate new reasonable, articulable suspicion arising during a stop)
State v. Simons, 296 P.3d 721 (Utah 2013) (overall course of action during a stop must be reasonably directed to proper ends)
State v. Gurule, 321 P.3d 1039 (Utah 2013) (inherent danger of traffic stops relevant to totality of circumstances)
State v. Morris, 259 P.3d 116 (Utah 2011) (reasonable suspicion is a low threshold distinct from probable cause)
State v. Roybal, 232 P.3d 1016 (Utah 2010) (reasonable suspicion often based on officer’s observations and inferences)
State v. Houston, 263 P.3d 1226 (Utah Ct. App. 2011) (officer’s recent verification of status can support reasonable suspicion)
State v. Holt, 780 S.E.2d 44 (Ga. Ct. App.) (delay around thirty minutes during investigatory stop not per se unreasonable)