United States v. Angulo, 5:16-cr-04102

On Dec. 8, 2016, Deputy Tadlock stopped a vehicle on I-29 for minor lane/fog-line violations; Samantha Linaman was a front-seat passenger. The initial stop was lawful and resulted in a written warning to the driver, Trimble.
During the stop the three occupants displayed nervous behavior; Trimble searched his phone for insurance, and the occupants gave explanations about travel from Las Vegas and picking up a passenger whose car broke down in Nebraska.
After issuing the warning and returning IDs, Tadlock asked for consent to search; consent was refused. Tadlock then ordered the occupants into patrol cars and conducted a drug-dog sniff; the dog alerted and officers searched the vehicle, finding >20 pounds of methamphetamine in a backpack.
Linaman moved to suppress evidence obtained after the dog sniff, arguing the officer unlawfully extended the completed traffic stop without reasonable, articulable suspicion.
The magistrate judge held an evidentiary hearing, credited Tadlock’s training and observations, but found the totality of facts insufficient to establish reasonable suspicion to prolong the stop.
The court recommended suppression of the physical evidence and any statements obtained after the unlawful extension, because the prolonged detention was the but-for cause and the government did not invoke any exceptions to the exclusionary rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prolonging the traffic stop to conduct a dog sniff violated the Fourth Amendment	Govt: Officer had reasonable, articulable suspicion based on occupants’ unusual nervousness, travel from Las Vegas (a drug source city), minor inconsistencies in stories, and suspicious travel plans	Linaman: The stop was completed once the warning was issued; the subsequent dog sniff unlawfully extended the seizure absent reasonable suspicion	Court: No — under the totality of circumstances, Tadlock lacked reasonable suspicion to extend the stop for a dog sniff
Whether evidence found after the sniff should be suppressed as fruit of the poisonous tree	Govt: (did not press exceptions at hearing)	Linaman: All evidence and statements resulting from the prolonged detention must be suppressed	Court: Recommended suppression of physical evidence and statements because the unlawful extension was the but-for cause and no exception was argued by the government

United States v. Woods, 829 F.3d 675 (8th Cir. 2016) (reasonable-suspicion standard for prolonging traffic stops and dog sniffs)
Rodriguez v. United States, 135 S. Ct. 1609 (2015) (police may not extend a completed traffic stop absent reasonable suspicion)
Terry v. Ohio, 392 U.S. 1 (1968) (foundation for reasonable, articulable suspicion standard)
Arizona v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances assessment for reasonable suspicion)
United States v. Beck, 140 F.3d 1129 (8th Cir. 1998) (factors that may be insufficient for reasonable suspicion)
United States v. Jones, 269 F.3d 919 (8th Cir. 2001) (limited weight of ordinary nervousness in reasonable-suspicion analysis)