United States v. Frazier, 467 F.Supp.3d 1144

On Nov. 12, 2019, Utah Highway Patrol Trooper Adam Gibbs stopped Antoine Frazier’s rental SUV after visually estimating and pacing it at ~85 mph in an 80 mph zone and observing two signal violations.
During a passenger‑side contact Gibbs noted a duffel bag in the cargo area, a deodorizer, the driver’s reluctance to lower the window, and inability initially to produce a rental agreement.
While preparing a citation and running checks, Gibbs used DEASIL (vehicle travel history) and called the rental company to verify authorization; he also summoned a certified narcotics K‑9 handler.
Deputy Peterson deployed certified K‑9 Bolos for a free‑air sniff; Bolos alerted at the driver’s door around 9:26 a.m.
After the alert officers detained and patted down Frazier, found a firearm, arrested him, and searched the vehicle; they discovered large quantities of suspected fentanyl/oxycodone pills and a brick of suspected cocaine.
The court denied Frazier’s suppression motion, holding the stop justified at inception, the detention’s scope and duration lawful, and Bolos’ alert provided probable cause for the search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Was the traffic stop justified at inception?	Trooper lacked reasonable suspicion to stop for a moving violation.	Trooper observed speeding (radar/pacing) and two inadequate turn signals, providing objective basis for the stop.	Stop was lawful: pacing, radar confirmation, and two signal violations gave reasonable suspicion.
2) Did the detention exceed the scope/duration permitted by the Fourth Amendment?	Trooper unreasonably prolonged the stop (canine deployment and additional checks) beyond mission of traffic stop.	Trooper diligently pursued citation, license/warrant checks, rental verification, and safety measures; canine sniff did not unreasonably prolong stop.	Detention was reasonably related to the stop; officer acted with due diligence and developed suspicion to extend the stop.
3) Was there probable cause to search the vehicle?	Canine alert insufficient or unreliable to establish probable cause.	K‑9 Bolos was certified, performed proper free‑air sniff, and alerted on driver’s door, providing probable cause.	Probable cause existed: trained K‑9’s alert (Boloss’ certification and proper deployment) justified the vehicle search.

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigatory‑stop Fourth Amendment standard)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during lawful traffic stop not per se unconstitutional if it doesn’t prolong stop)
Rodriguez v. United States, 575 U.S. 348 (2015) (duration of a traffic stop must be limited to mission; extensions require reasonable suspicion)
Florida v. Harris, 568 U.S. 237 (2013) (certified canine alert can establish probable cause)
United States v. Arvizu, 534 U.S. 266 (2002) (reasonable‑suspicion analysis based on totality of circumstances and officer training)
United States v. Sharpe, 470 U.S. 675 (1985) (stop duration evaluated for reasonableness under the circumstances; no per se time limit)
United States v. Mayville, 955 F.3d 825 (10th Cir. 2020) (affirming that a canine sniff during a lawful stop can provide probable cause and is permissible if not unreasonably prolonging the stop)