United States v. Cleola Sullivan, 16-17636

DEA investigation after Jarrick Williams was arrested with 420g cocaine; Williams identified Sullivan as his primary supplier and said she hid cocaine under her car bumper; Williams agreed to controlled communications with Sullivan.
DEA obtained a GPS warrant for Sullivan’s phone, tracked her movements, and conducted physical surveillance when she neared Florida and later Georgia; controlled calls/texts arranged a cocaine delivery.
Officers lost surveillance when Sullivan deviated from expected route; Alachua County officers were asked to stop her using independently obtained probable cause.
Sullivan was stopped for following too closely; officers ran her information, issued a written traffic warning, and initially obtained her consent to search; they continued searching after the warning, performed a dog sniff, and the dog alerted to the bumper.
Officers transported the vehicle to the sheriff’s office, found a sock tied under the rear bumper containing ~0.5 kg cocaine, and Sullivan made inculpatory statements; she was indicted and moved to suppress the evidence and statements.
District court denied suppression, concluding consent expired with the traffic stop but collective officer knowledge (informant tip, controlled communications, GPS surveillance) established probable cause to search; Sullivan was convicted and appealed.

Issue	Sullivan's Argument	Government's Argument	Held
Whether officers unreasonably prolonged stop/search after issuing traffic warning	Continued detention/search after warning lacked probable cause; consent expired	Officers had probable cause based on informant tip, GPS, controlled calls/texts, and shared officer knowledge	Court held probable cause existed, so continued detention/search lawful
Whether consent to search covered the dog sniff and subsequent search	Consent did not extend to dog sniff and expired with the traffic stop	Independent probable cause existed regardless of consent or dog alert	Court did not rely on consent/dog; found probable cause independent of dog sniff
Whether the dog alert was a reliable basis for probable cause	Argues dog sniffs are unreliable and this dog was insufficiently reliable	Dog alert occurred but court said probable cause was established independent of it	Court declined to decide dog reliability because probable cause existed without it
Whether collective knowledge of officers can be aggregated to establish probable cause	Sullivan disputed that aggregated, inter-officer information sufficed	Government relied on aggregation doctrine since officers maintained communication	Court accepted aggregation and found probable cause based on collective information

United States v. Lewis, 674 F.3d 1298 (11th Cir. 2012) (standard of review for suppression rulings)
United States v. Brundidge, 170 F.3d 1350 (11th Cir. 1999) (deference given to district court probable cause findings)
United States v. Tamari, 454 F.3d 1259 (11th Cir. 2006) (automobile exception to warrant requirement requires mobility and probable cause)
United States v. Talley, 108 F.3d 277 (11th Cir. 1997) (probable cause standard for vehicle searches)
United States v. Campbell, 920 F.2d 793 (11th Cir. 1991) (probable cause formulation cited)
United States v. Willis, 759 F.2d 1486 (11th Cir. 1985) (collective knowledge doctrine when officers maintain communication)
United States v. Newsome, 475 F.3d 1221 (11th Cir. 2007) (review of suppression rulings considers entire record)