State v. Westcott, 385 P.3d 1268

Police, investigating a house identified by a reliable tip as a site of methamphetamine sales, observed three short visits resulting in drug arrests and a fourth visitor (no drugs found).
Officers surveilled the house while awaiting a search warrant and observed defendant make three short visits in one hour—each visit about 10 minutes—parking behind the house each time.
After the third visit, officers suspected the car’s occupants were holding drugs, followed the vehicle, and stopped it for a traffic violation (a lawful initial stop).
At the stop, officers (who recognized defendant and his passenger as known drug-involved persons) noted defendant’s pronounced nervousness; defendant refused consent to search and officers summoned a drug-detection dog.
About 30 minutes later the dog alerted, officers searched, found methamphetamine on defendant, and he was arrested; defendant moved to suppress evidence as an unlawful extension of the traffic stop.
Trial court granted suppression under Article I, § 9 (Oregon Constitution); the state appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had objective reasonable suspicion to extend a traffic stop into a drug investigation	State: contemporaneous facts (repeated short visits to a house where drug sales were confirmed; defendant known to be drug-involved; pronounced nervousness) amounted to reasonable suspicion	Defendant: facts were associative and common (presence at a known drug location, known drug user, nervousness) and insufficient to elevate a hunch into reasonable suspicion	Court reversed suppression: totality of facts (confirmed sales at that specific house, three short visits in one day, similarity to other purchasers, known drug involvement, marked nervousness) suffice for reasonable suspicion to extend the stop

State v. Carter I Dawson, 287 Or. 479, 600 P.2d 873 (1979) (officer motive irrelevant to validity of a lawful traffic stop)
State v. De La Rosa, 228 Or. App. 666, 208 P.3d 1012 (2009) (pretext stops permissible when otherwise lawful)
State v. Rodgers/Kirkeby, 347 Or. 610, 227 P.3d 695 (2010) (distinguishes permissible traffic detentions from extensions that require reasonable suspicion)
State v. Holdorf, 355 Or. 812, 333 P.3d 982 (2014) (reasonable suspicion assessed by totality of circumstances; must be specific and articulable)
State v. Wiggins, 262 Or. App. 351, 324 P.3d 626 (2014) (presence in a drug area and past drug use insufficient alone for reasonable suspicion)
State v. Rutledge, 243 Or. App. 603, 260 P.3d 532 (2011) (brief visit to suspected drug location and nervousness did not create reasonable suspicion)
State v. Bertsch, 251 Or. App. 128, 284 P.3d 502 (2012) (association with drug users and presence at a location associated with drugs are weak indicators)
State v. Huffman, 274 Or. App. 308, 360 P.3d 707 (2015) (nervousness plus conduct suggesting concealment can support reasonable suspicion when combined with other facts)
State v. Barber, 279 Or. App. 84, 379 P.3d 651 (2016) (possible observed drug activity in the car can transform otherwise weak location-based facts into reasonable suspicion)