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

On Dec. 13, 2016 an indictment charged Samantha Linaman with conspiracy and possession with intent to distribute methamphetamine. Linaman moved to suppress evidence seized after a traffic stop and her post‑arrest statements.
Deputy Tadlock stopped a vehicle on I‑29 for lane/fog‑line crossings after following it for several minutes overnight; he checked licenses, registration, and insurance and issued a written warning.
During the stop Tadlock questioned occupants, observed nervous behavior (shaking hands, avoiding eye contact), learned travel from Las Vegas and hub‑city source information from interdiction training, and briefly reviewed Trimble’s phone for insurance info.
After issuing the warning and returning IDs, Tadlock requested consent to search; Trimble refused. Tadlock then had a drug‑detection dog sniff the exterior; the dog alerted and officers found ~20 pounds of methamphetamine in a backpack.
Magistrate Judge Mahoney recommended suppression, concluding the dog sniff unlawfully prolonged the stop without reasonable suspicion; the district judge adopted the R&R and granted the motion to suppress all evidence and post‑arrest statements.

Issue	Plaintiff's Argument (Gov't)	Defendant's Argument (Linaman)	Held
Whether the officer unlawfully prolonged a traffic stop by conducting a canine sniff after completing tasks related to the stop	The totality of circumstances (nervousness, travel from Las Vegas, source‑city training, odd statements, delayed insurance search) gave reasonable suspicion to detain for a dog sniff	The stop was completed when routine tasks and the warning were finished; the dog sniff unlawfully extended the seizure absent independent reasonable suspicion	Court held the stop was unconstitutionally prolonged; canine sniff violated the Fourth Amendment and evidence from the subsequent search was suppressed
Whether Linaman’s post‑arrest statements are admissible or fruit of the unlawful detention	Admission: statements were voluntary and not causally tainted	Statements flowed from the unlawful prolonged detention and the ensuing search, so they are fruit of the poisonous tree	Court suppressed Linaman’s post‑arrest statements as fruit of the unconstitutional detention

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (officers may not extend a traffic stop to conduct unrelated checks, like a dog sniff, absent reasonable suspicion)
United States v. Beck, 140 F.3d 1129 (8th Cir. 1998) (traffic violation, however minor, supplies probable cause for a stop)
United States v. Bloomfield, 40 F.3d 910 (8th Cir. 1994) (reasonable‑suspicion inquiry uses the totality of the circumstances and officer experience)
United States v. Lyons, 486 F.3d 367 (8th Cir. 2007) (reasonable suspicion requires more than an inchoate hunch)
Anderson v. City of Bessemer City, 470 U.S. 564 (1985) (clearly erroneous standard explained for factual review)