United States v. Crayton, 2:23-cr-00045

Robert Crayton and Immanuel Woodberry were stopped by Detective Anderson in Indiana for speeding while driving a rental car from Atlanta to Chicago.
Performing a rental history check and discussing travel plans, Anderson became suspicious based on the car's recent locations and the defendants’ brief trip pattern.
After refusing consent to search the vehicle, Anderson had a drug-sniffing dog (Fena) conduct a sniff; Fena alerted to the car, prompting a search yielding cocaine.
Crayton and Woodberry moved to suppress the evidence from the stop and search, arguing Fourth Amendment violations, pretext, and improper dog search practices.
Crayton also sought to suppress statements made in Anderson's patrol car and requested additional briefing based on newly produced officer messages.
The District Court denied the suppression motions and Crayton’s request for further briefing, finding the stop lawful, not unduly prolonged, and that reasonable suspicion and probable cause existed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawfulness of traffic stop	Crayton: Stop was pretextual, and start time earlier.	Gov't: Stop lawful for speeding, supported by police experience.	Stop was lawful, justified by observed speeding.
Prolongation of stop for dog sniff	Crayton: Stop was impermissibly prolonged for dog arrival.	Gov't: Stop duration reasonable, dog arrived promptly; suspicion.	No unlawful prolongation; suspicion justified.
Reasonable suspicion for prolonged detention	Crayton: No adequate suspicion for further detention.	Gov't: Facts from stop/travel plans built suspicion.	Sufficient suspicion to prolong detention.
Lawfulness/reliability of dog sniff and search	Woodberry: No valid alert, no consent to interior search.	Gov't: Dog's alert reliable, provided probable cause.	Dog alert reliable; search was lawful.
Evidence suppression on grounds of pretext/race	Crayton: Officer's messages showed racial pretext.	Gov't: Motivation irrelevant; message not material.	Motivation immaterial; suppression denied.
Suppression of statements made in patrol car	Crayton: Statements are fruit of unlawful detention.	Gov't: Detention was lawful, statements voluntary.	Suppression of statements denied.

Whren v. United States, 517 U.S. 806 (pretextual traffic stops are constitutional if supported by a traffic violation)
Rodriguez v. United States, 575 U.S. 348 (dog sniffs that prolong stops require independent reasonable suspicion)
Arizona v. Johnson, 555 U.S. 323 (traffic stop begins when vehicle is pulled for investigation)
Brendlin v. California, 551 U.S. 249 (passengers seized during a traffic stop have standing to challenge stop)
Florida v. Harris, 568 U.S. 237 (reliable, certified narcotics dog's alert provides probable cause for a vehicle search)
United States v. Cole, 21 F.4th 421 (reasonable suspicion required to justify a routine traffic stop)
Kansas v. Glover, 589 U.S. 376 (reasonable suspicion may consider probabilities and officer experience)
Hiibel v. Sixth Jud. Dist. Ct. of Nevada, Humboldt Cnty., 542 U.S. 177 (stop must be justified at inception and related in scope to justification)
United States v. Street, 917 F.3d 586 (neutral descriptive characteristics like race, sex, and age are legitimate for identification)