United States v. Angulo-Gaxiola, 4:23-cr-00039

Background

On March 18, 2023, Sevier County Deputy Bodee Wells stopped Said Angulo‑Gaxiola’s truck for allegedly illegal dark window tint; Said lacked a U.S. driver’s license and produced a U.S. border crossing card; passenger Saul produced a Mexican license only later.
Wells, a very recently trained patrol deputy, did not initially request the truck’s registration or proof of insurance and delayed obtaining the passenger’s Mexican license until ~20 minutes into the stop.
Sgt. Aaron Richards (supervising) arrived; Richards called for a K‑9 around the 15‑minute mark; Trooper Bagley (K‑9) arrived ~26 minutes after stop initiation; the dog sniff began ~29 minutes into the stop and quickly alerted.
A subsequent search produced ~50 pounds of suspected methamphetamine and ~2.5 pounds of suspected fentanyl; Said moved to suppress evidence and statements obtained after the allegedly prolonged stop.
The court found the stop was unreasonably prolonged by officer delinquency and by a diversion to await a K‑9 without reasonable suspicion, and granted Said’s motion to suppress.

Issues

Issue	Plaintiff's Argument (Government)	Defendant's Argument (Said)	Held
Whether the stop lasted longer than reasonably necessary	Officers diligently pursued stop tasks; delays were imperfect but not unreasonable	Wells’ failures (not getting registration/insurance, mishandling IDs) unreasonably prolonged the stop	Court: Stop was unreasonably prolonged by officer delinquency and failures to follow procedure (Fourth Amendment violated)
Whether officers diverted from traffic mission to arrange a K‑9 (the Rodriguez moment)	No unlawful diversion; if diversion occurred it was supported by reasonable suspicion	Diversion occurred when Saul’s license was handed to Richards and officers then waited for K‑9 to arrive	Court: Diversion occurred (~5.5 minutes initially, K‑9 arrived later), and it prolonged the stop in violation of Rodriguez
Whether officers had reasonable suspicion to justify extending the stop	Facts (all windows down, origin from Sinaloa, travel plans, nervousness, offers to remove tint, staring, volunteered info) supported reasonable suspicion	Those facts are innocent or minimal (ordinary nervousness, inconsistent geography, travel not implausible); only hunches	Court: Totality of facts did not yield particularized, objective reasonable suspicion; government failed to justify the extension
Remedy for Fourth Amendment violation	Evidence admissible because officers acted reasonably / dog sniff lawful	Suppress all physical evidence and statements obtained after the unlawful extension	Court: Exclusionary rule applies; suppressed the evidence and statements obtained after the unlawful extension

Key Cases Cited

Rodriguez v. United States, 575 U.S. 348 (2015) (traffic stop mission limits duration; extensions require reasonable suspicion)
Illinois v. Caballes, 543 U.S. 405 (2005) (K‑9 sniff during traffic stop is a sniff, and extension is unlawful if it measurably prolongs the stop without reasonable suspicion)
United States v. Frazier, 30 F.4th 1165 (10th Cir. 2022) (arranging a dog sniff can unlawfully prolong a stop; reasonable suspicion required for extensions)
United States v. Cortez, 965 F.3d 827 (10th Cir. 2020) (officer diligence can justify short delays; facts there supported reasonable suspicion after seven minutes)
United States v. Leon, 80 F.4th 1160 (10th Cir. 2023) (evaluate police diligence; travel‑related factors have limited probative value)
United States v. Cates, 73 F.4th 795 (10th Cir. 2023) (distinguishes situations where arranging a dog sniff does not unreasonably prolong a stop when officer diligently pursues traffic tasks)
United States v. Mayville, 955 F.3d 825 (10th Cir. 2020) (officer authority ends when tasks tied to the traffic infraction are—or reasonably should have been—completed)