State v. Taylor, 479 P.3d 620

Around midnight Officer Bazer followed and stopped a silver Mercedes after observing brake lights and the car stopping past the crosswalk line; an earlier radio report had mentioned a Mercedes in a shooting.
During the stop Bazer noticed defendant’s hands shaking, a rolled bundle of U.S. currency in her wallet, a sleepy passenger, and that defendant said she had been staying at the Crosslands Motel (which Bazer associated with drug activity) and had not registered the car in her name.
After running records with no warrants, Bazer requested a drug-dog officer (Sorby); Sorby told defendant he would likely walk a dog around the car and asked if there was anything illegal inside.
Defendant then told the officers she had a “dirty needle” in her purse; officers searched the vehicle and found heroin/meth residue and a handgun; defendant was charged with felon-in-possession (FIP). The state did not charge drug crimes.
Defendant moved to suppress the evidence on the ground that Bazer unlawfully extended a traffic stop into a drug investigation without reasonable suspicion; the trial court denied suppression, convicted after a stipulated-facts trial, and defendant appealed.
The Court of Appeals held the trial court erred: the officer lacked objective reasonable suspicion to shift to a drug investigation and the improper extension was not harmless because the handgun was the essential evidence for the FIP conviction. Case reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer had objective reasonable suspicion to extend a lawful traffic stop into a drug investigation	Bazer had reasonable suspicion based on (1) rolled cash, (2) recent presence at a motel associated with drug activity, (3) extreme nervousness, and (4) the late hour	These facts individually and collectively did not supply specific, articulable facts that drugs were involved; the extension was unlawful under Article I, §9	The court held there was no objective reasonable suspicion; the stop’s expansion into a drug investigation was unlawful and suppression error was not harmless

State v. Maciel-Figueroa, 361 Or 163 (establishes reasonable-suspicion framework for investigative stops)
State v. Arreola-Botello, 365 Or 695 (limits traffic-stop inquiries to matters related to the stop or independently justified)
State v. Huffman, 274 Or App 308 (nervousness tied to other suspicious conduct can support reasonable suspicion)
State v. Decker, 290 Or App 321 (nervousness unlinked to drugs is insufficient for reasonable suspicion of narcotics)
State v. Kennedy, 45 Or App 911 (possession of cash alone is insufficient to infer drug trafficking)
State v. Bertsch, 251 Or App 128 (presence in a location associated with drug activity, without more, is insufficient)
State v. Schmitz, 299 Or App 170 (training and experience cannot substitute for articulable facts)
State v. Bates, 304 Or 519 (high-crime area or late hour alone do not establish a particular person’s criminality)