State v. Norvet, 2016 Ohio 3494

Trooper Jared Hasler stopped James Norvet on I-71 for following too closely and a marked-lane drift; Norvet made repeated reaches toward the glove/ passenger floor area during the stop.
Hasler began computer checks and intended to issue a written warning; shortly after Trooper Dave Norman and a canine arrived (less than 4 minutes after Norman’s arrival the dog sniff occurred).
The canine alerted to the vehicle; officers then searched and found a loaded 9mm handgun in the locked glove compartment and ammunition in a backpack.
Norvet moved outside the vehicle and was patted down with consent; he disputed some trial facts (denying he told officers about the gun and that he heard Miranda warnings).
Norvet moved to suppress evidence arguing the dog sniff/deployment impermissibly extended the traffic stop; the suppression motion was denied, he pleaded no contest, and was sentenced to community control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the canine sniff unlawfully prolonged the traffic stop, making the detention unconstitutional	State: Dog sniff occurred while the stop was ongoing and before tasks were completed; a sniff of a lawfully detained car is permissible	Norvet: The dog sniff occurred after the traffic stop’s mission ended and thus unreasonably prolonged the seizure	Court: Denied suppression — detention was not unlawfully prolonged; sniff occurred before purpose of stop was effected and within reasonable time

State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (appellate standard for review of suppression rulings)
State v. Batchili, 113 Ohio St.3d 403 (Ohio 2007) (officer may detain long enough to complete tasks incident to stop)
State v. Carlson, 102 Ohio App.3d 585 (Ohio App. 1995) (canine sniff permissible during a lawful traffic detention; alert supplies probable cause)
Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (traffic-stop seizure becomes unlawful if prolonged beyond time reasonably required to complete mission)