United States v. Coker, 648 F. App'x 541

At ~2:44–2:47 AM in rural Tennessee Officer McCullough observed Jeris Coker cross a double-yellow line and stopped his vehicle; McCullough had probable cause for the traffic stop.
During the stop McCullough observed Coker repeatedly move inside the car (leaning forward, reaching into the backseat) and stare intently; Coker appeared nervous and said he was nervous about license points.
After dispatch confirmed no outstanding warrants, McCullough extended the stop to ask drug-related questions and requested consent to search; Coker refused.
McCullough then asked Coker to exit, performed a pat-down for officer safety, found an empty holster, and handcuffed him.
A drug dog arrived ~39 minutes after the initial stop, alerted to the vehicle, and officers searched the car, discovering a loaded handgun; Coker pleaded guilty to being a felon in possession.
The district court denied Coker’s suppression motion; the Sixth Circuit majority affirmed the denial, while a dissenting judge would have found the extension lacked reasonable suspicion.

Issue	Coker's Argument	Government/Officer's Argument	Held
1) Was the initial traffic stop lawful?	Stop was pretextual/invalid	Officer had probable cause based on double-yellow line violation	Held lawful — probable cause to stop under Whren and state code
2) Could officer lawfully extend the stop to investigate unrelated criminal activity?	Movements/nervousness/time insufficient for reasonable suspicion	Movements (reaching/digging), nervousness, and late hour together supplied reasonable suspicion	Held lawful — totality of facts gave reasonable suspicion to extend (majority)
3) Was a pat-down for weapons justified?	Movements did not show armed and dangerous risk	Continued reaching after commands, staring, and nervousness provided reasonable suspicion he was armed and dangerous	Held lawful — officer reasonably suspected Coker might be armed
4) Did the drug-dog alert and subsequent vehicle search violate the Fourth Amendment?	Dog alert unreliable; stop too long	Trained dog alerted, giving probable cause; ~39-minute duration acceptable given suspicion and dog arrival	Held lawful — dog alert supplied probable cause; search upheld

Whren v. United States, 517 U.S. 806 (officer may stop vehicle when probable cause to believe traffic violation occurred)
Rodriguez v. United States, 575 U.S. 348 (officer may not extend stop beyond traffic tasks absent reasonable suspicion)
Navarette v. California, 572 U.S. 393 (reasonable suspicion requires only a minimal level of objective justification)
Illinois v. Wardlow, 528 U.S. 119 (contextual factors like flight or presence in high-crime area inform reasonable suspicion)
Ornelas v. United States, 517 U.S. 690 (reasonable-suspicion and probable-cause determinations reviewable de novo with respect to legal principles)
Florida v. Harris, 568 U.S. 237 (a properly trained drug dog’s alert can establish probable cause)
Arizona v. Johnson, 555 U.S. 323 (pat-down justified by reasonable suspicion that a person is armed and dangerous)
Illinois v. Caballes, 543 U.S. 405 (traffic-stop detention must not last longer than necessary absent reasonable suspicion)
United States v. Sokolow, 490 U.S. 1 (nervousness can be a factor in reasonable-suspicion analysis)
Reid v. Georgia, 448 U.S. 438 (Fourth Amendment forbids seizures based on little or no objective justification)