State v. Rennis, 90 A.3d 906

Hartford, Vermont Border Patrol checkpoint operates with primary and secondary inspections to locate illegal entrants or contraband.
Defendant stopped at the primary site; he claimed U.S. citizenship, but stated Jamaica birth; identified as a legal permanent resident without immigration papers.
Agent suspected marijuana odor; defendant admitted some marijuana use; directed to the rest area for secondary inspection.
A drug-detection dog sniff at the ramp did not alert initially; during later sniff, dog alerted; defendant admitted marijuana in the car.
At secondary inspection, trunk searched, backpack opened; two pounds of marijuana found; drugs seized and referred to ICE, which declined prosecution; state prosecution followed.
Defendant moved to suppress under Fourth Amendment and Vermont Constitution Article 11; trial court denied; defendant pled guilty to possession pending appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Article 11 excludes the evidence seized by federal officers at the Hartford checkpoint.	Coburn controls; federal border interests trump Vermont interests; Article 11 does not apply.	Cardenas-Alvarez would require suppression when federal seizure is lawful under federal law but unlawful under Vermont Constitution.	Article 11 does not apply; suppression not warranted.

State v. Coburn, 165 Vt. 318 (1996) (federal interests at the border preempt Vermont constitutional limits; shared knowledge doctrine)
United States v. Martinez-Fuerte, 428 U.S. 543 (1976) (functional equivalent of the border for checkpoints; reasonableness of border searches)
Almeida-Sanchez v. United States, 413 U.S. 266 (1973) (border search doctrine and distance from border; limitations on state interest)
State v. Dreibelbis, 147 Vt. 98 (1986) (Article 11 applicability when federal searches are lawfully conducted)
State v. Cardenas-Alvarez, 2001-NMSC-017 (2001) (state suppression rule may differ from federal law; not controlling here)