United States v. Johnson, 1:21-cr-00017

At ~11:00 p.m., Deputy Haber followed a white SUV that he observed the driver turn away from and appear to hide his face; a plate check showed expired registration, so he initiated a traffic stop.
During the stop Deputy Haber learned Adrian Johnson’s license was suspended; Johnson provided a bill of sale and an ID and was towed/impounded because he lacked authority to drive and the vehicle was not registered to him.
Johnson consented to a pat-down; officers found $1,600 in cash. Deputy Haber then deployed K-9 Rico for a free air sniff while Johnson was placed in the back of a patrol car (not handcuffed initially).
Rico alerted on the passenger side; deputies searched the vehicle and found methamphetamine (mixed with fentanyl), a pipe, a handgun with an obliterated serial number, and ammunition.
Johnson moved to suppress the vehicle search as an unlawful warrantless search, arguing he was effectively under arrest and secured in the patrol car before the dog sniff and search (invoking Arizona v. Gant). The government argued the dog alert supplied probable cause and the automobile exception justified the search.
The court denied the motion: it found the stop lawful, the canine alert provided probable cause, and the automobile exception permitted a warrantless search; alternatively, reasonable suspicion justified any brief extension for the sniff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of the warrantless vehicle search	Gov: Free air sniff by trained K-9 produced an alert that gave probable cause; automobile exception permits full vehicle search; stop was lawful and sniff did not meaningfully prolong it	Johnson: He was seized/under arrest in patrol car before the sniff; under Gant a search incident to arrest was invalid because he was not within reaching distance and the arrest offense (suspended license) did not justify searching for evidence	Court denied suppression: canine alert + objective facts (behavior, slow stop, large cash) supplied probable cause; automobile exception applied; even if sniff extended the stop, reasonable suspicion justified detention

Whren v. United States, 517 U.S. 806 (traffic stop lawful when officers have probable cause of a traffic violation)
Arizona v. Gant, 556 U.S. 332 (limits on vehicle searches incident to arrest)
Illinois v. Caballes, 543 U.S. 405 (drug-sniffing dog may conduct free air sniff during traffic stop if it does not prolong the stop)
Rodriguez v. United States, 575 U.S. 348 (police may not extend a traffic stop without reasonable suspicion)
United States v. Ross, 456 U.S. 798 (automobile exception permits searching compartments where contraband may be hidden)
United States v. Guidry, 817 F.3d 997 (dog alert provides probable cause to search a vehicle)
United States v. Edwards, 769 F.3d 509 (distinguishing Gant's arrest-tied standard from automobile-exception probable cause standard)
Ornelas v. United States, 517 U.S. 690 (giving due weight to officers' training and experience in reasonable suspicion assessment)