State v. Phillip Emmanuel Taylor, 05-15-01542-CR

Background

Early morning traffic stop: Deputy Manning stopped Phillip Taylor’s Infiniti for a partially lit license-plate lamp; Deputy Hoover stopped a following Toyota pickup for following too closely. Both vehicles displayed Tennessee plates and were registered to Taylor.
Hoover observed the two vehicles at a truck stop earlier; occupants conversed and then separated when he approached, which Hoover found suspicious.
After confirming licenses/registration and absence of warrants, Manning asked Taylor for consent to search the Infiniti; Taylor refused. Manning completed traffic-stop tasks within about 17–35 minutes but then waited for a canine unit.
Hoover (or another officer) called a Kaufman County canine officer; the canine arrived about 56–69 minutes after the stop had otherwise concluded. The dog alerted and officers then smelled a strong odor of raw marijuana and found ~100 lbs. of marijuana.
Taylor moved to suppress the marijuana as the product of an unlawful prolonged detention; the trial court granted the motion, finding the additional 56–69 minute detention to wait for the dog was illegal. The State appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether continued detention after traffic tasks were completed was supported by reasonable suspicion	State: officers had individualized & collective reasonable suspicion (tandem travel, statements, registration link, suspicious conduct) justifying waiting for a K-9	Taylor: stop’s mission ended once traffic checks were done; prolonging to wait for dog without new reasonable suspicion violated the Fourth Amendment	Court: Held detention was unreasonable; suppression affirmed
Whether the length of the delay (56–69 minutes) was reasonable as a matter of law	State: cited cases permitting waits for canine where narcotics investigation was justified	Taylor: Rodriguez bars prolonging stop to conduct dog sniff absent new suspicion; length was excessive	Court: Length unreasonable under Rodriguez/Sharpe; no new reasonable suspicion during waiting period
Whether collective knowledge of officers supplied reasonable suspicion	State: facts across officers (gas station meeting, tandem travel, inconsistent statements, registration to same owner) cumulatively established suspicion	Taylor: those facts were innocent or weakly probative; officers did not diligently pursue other lines and delayed calling K-9	Court: Collective facts did not establish reasonable suspicion to extend detention; credibility/inconsistencies supported suppression
Whether post-arrival observations (dog alert, then odor) cure prior illegality	State: points to dog alert and ensuing odor as justification for search/seizure	Taylor: canine and odor came after unlawful prolongation; cannot cure earlier Fourth Amendment violation	Court: Agreed; later discovery did not validate the prior unconstitutional detention

Key Cases Cited

Arguellez v. State, 409 S.W.3d 657 (Tex. Crim. App. 2013) (standard of review for suppression rulings)
State v. Story, 445 S.W.3d 729 (Tex. Crim. App. 2014) (abuse-of-discretion review limits)
Kerwick v. State, 393 S.W.3d 270 (Tex. Crim. App. 2013) (deference to fact findings and review of mixed questions)
Derichsweiler v. State, 348 S.W.3d 906 (Tex. Crim. App. 2011) (reasonable suspicion requirements)
Castro v. State, 227 S.W.3d 737 (Tex. Crim. App. 2007) (articulable facts test for reasonable suspicion)
Kothe v. State, 152 S.W.3d 54 (Tex. Crim. App. 2004) (scope/duration of traffic stops)
Rodriguez v. United States, 575 U.S. 348 (U.S. 2015) (prohibits prolonging a traffic stop to conduct a dog sniff absent independent reasonable suspicion)
United States v. Sharpe, 470 U.S. 675 (U.S. 1985) (diligence/duration inquiry for investigative detentions)
Florida v. Royer, 460 U.S. 491 (U.S. 1983) (temporariness of traffic stops)
Mathews v. State, 431 S.W.3d 596 (Tex. Crim. App. 2014) (distinguishable narcotics-focused investigation where canine delay was upheld)