State v. Pichardo, 326 P.3d 624

Officer Long stopped defendant based on observed traffic issue and Hamilton's description suggesting obstruction; stop supported by reasonable suspicion.
Defendant was detained, car searched with consent after he admitted heroin in his pocket; subsequent consent to search the car revealed drugs.
Trial court denied suppression; defendant pleaded no contest and appealed challenging the stop and search under Article I, section 9.
State argued stop was lawful due to objective suspicion and that any drug inquiry was permissible if incidental to the stop; attenuation argued if illegal.
Court held initial stop lawful but Long unlawfully extended the stop by asking about drugs without reasonable suspicion; suppression of evidence ordered; case reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the initial stop supported by reasonable suspicion?	Long had reasonable suspicion to stop.	No reasonable suspicion for drug-related stop.	Yes, initial stop lawful.
Did asking about drugs extend the stop without reasonable suspicion?	Questions unrelated to the stop are permissible.	Drug inquiry extended stop unlawfully.	Unlawful extension; suppression required.
Is the drug-related consent attenuated from illegality?	Consent independent of misconduct.	Consent tainted by unlawful stop.	Not attenuated; suppression upheld.

State v. Rodgers/Kirkeby, 347 Or 610 (2010) (reasonable-suspicion trigger for traffic stop and inquiry)
State v. Ehly, 317 Or 66 (1993) (two-component test for reasonable suspicion; deference to factual findings)
State v. Huggett, 228 Or App 569 (2009) (extension of stop requires reasonable suspicion; avoidance of lull tactic)
State v. Klein, 234 Or App 523 (2010) (drug-related questions during lawful stop taint the stop if unsupported by suspicion)
State v. Jimenez, 263 Or App 150 (2014) (unlawful extension by drug inquiry; suppression appropriate)