State v. Pylican, 477 P.3d 180

Late-night (≈11:55 p.m.) deputy observed a Mazda enter a gated storage facility after posted hours; deputy had prior experience with after-hours access attempts and knew the area had recent theft reports.
The Mazda remained inside the facility for ~35 minutes; deputy did not observe overt criminal acts inside but watched vehicle movements and saw it exit after midnight.
Deputy followed the Mazda and initiated a traffic stop for a failure-to-signal; he also told Pylican he was stopping her for being in the storage facility after hours.
Pylican said she had entered before 10:00 p.m.; the deputy believed she was lying based on his observations. A K-9 unit arrived before the traffic stop was completed.
Deputy ordered Pylican and her passenger out of the car, the dog sniffed the vehicle, alerted on a backpack containing paraphernalia, and later meth was found; district court suppressed, Court of Appeals affirmed, Idaho Supreme Court reversed and remanded.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pylican)	Held
Whether deputy had reasonable suspicion to question Pylican about being in the storage facility after hours	Facts—entry after posted hours, prior unsuccessful after-hours attempts, high-theft area, and Pylican’s inconsistent statement—provided specific, articulable facts supporting reasonable suspicion	Presence in a high-crime area and being in the facility alone are innocent conduct; the deputy lacked particularized suspicion of wrongdoing	Court held the deputy had reasonable suspicion to question Pylican about presence in the facility
Whether ordering occupants out and conducting a K-9 sniff impermissibly extended the stop	Exit order was lawful under Mimms for officer safety; the K-9 sniff did not prolong the stop because the deputy continued traffic-stop tasks while the dog sniffed	Rodriguez and Linze prohibit detours for unrelated investigations that add time; ordering exit to facilitate a drug-dog search (absent drug-suspicion) unlawfully extended the stop	Court held the exit order did not unconstitutionally extend the stop—order was lawful and did not add time to the detention

Terry v. Ohio, 392 U.S. 1 (establishes standards for brief investigatory detentions)
Pennsylvania v. Mimms, 434 U.S. 106 (officers may order driver out during a lawful traffic stop for officer safety)
Rodriguez v. United States, 575 U.S. 348 (dog sniff that prolongs a stop requires independent reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (presence in high-crime area is a relevant, but not dispositive, factor for reasonable suspicion)
Navarette v. California, 572 U.S. 393 (reasonable suspicion need not rule out innocent conduct)
State v. Linze, 161 Idaho 605 (389 P.3d 150) (Idaho 2016) (dog-sweep/back-up activity that adds time to a stop can violate Rodriguez)
State v. Gonzales, 165 Idaho 667 (450 P.3d 315) (Idaho 2019) (totality-of-circumstances test for reasonable suspicion)