United States v. Ramdihall, 859 F.3d 80

Ramdihall and co-defendant Hillaire were indicted for conspiracy to possess/use counterfeit access devices; Ramdihall conditionally pled guilty preserving suppression claim and was sentenced to 10 months and restitution.
Three pretrial traffic stops produced evidence; on appeal Ramdihall challenges suppression denials for the Kittery, ME (Sept. 6, 2013) and Ohio (Oct. 10, 2013) stops.
Kittery: 1:30 a.m. encounter after 7‑Eleven clerk reported large gift‑card purchases; officers questioned occupants, inspected IDs, discovered electronics in trunk after Ramdihall verbally consented to a trunk check; officers seized computer equipment.
District Court found the Kittery encounter became a seizure at ~1:55 a.m.; it held officers had reasonable suspicion by that time, the 82‑minute detention was not unreasonably long, and the trunk search was consensual.
Ohio: trooper stopped the rental car for speeding; observed a plastic baggie in the center console which was quickly closed, noted rental circumstances and travel story inconsistencies, wrote a ticket, summoned a K‑9; the dog alerted and officers found 17 credit cards in the trunk, some counterfeit.
District Court held the six‑minute extension for the dog sniff was supported by reasonable suspicion based on the totality of circumstances (baggie concealment, rental anomalies, inconsistent travel story); swipe of recovered cards was not timely contested on privacy grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Kittery encounter was an unlawful seizure (timing)	Ramdihall: seizure occurred at initial 1:30 a.m. encounter (retention of license) so later evidence must be suppressed	Government: initial contact was investigatory; seizure began ~1:55 a.m. when officers prevented departure and had reasonable suspicion	Court: seizure began ~1:55 a.m.; no clear error in district court finding reasonable suspicion at that time
Whether Kittery detention became unreasonably long	Ramdihall: 82‑minute duration exceeded Terry limits	Government: length was proportional to investigative needs given murky facts and need to consult detective	Court: 82 minutes was lengthy but justified under Sharpe; not constitutionally unreasonable
Whether trunk search in Kittery was consensual	Ramdihall: consent was not voluntary due to coercive detention and officer presence	Government: no physical coercion; mild questioning and consent given verbally	Court: consent was voluntary under totality of circumstances; district court credibility not clearly erroneous
Whether Ohio stop was unlawfully extended for K‑9 sniff	Ramdihall: no reasonable suspicion developed; extension violated Rodriguez	Government: reasonable suspicion arose from surreptitious concealment of baggie, rental anomalies, travel inconsistencies, absence of luggage	Court: reasonable suspicion objectively supported brief extension for K‑9 sniff; denial of suppression affirmed

Terry v. Ohio, 392 U.S. 1 (Terry stop/reasonable suspicion standard)
United States v. Brignoni‑Ponce, 422 U.S. 873 (extension of Terry to vehicle stops)
United States v. Sharpe, 470 U.S. 675 (no rigid time limit on Terry stops; assess purpose and reasonable time)
Rodriguez v. United States, 135 S. Ct. 1609 (prolonging traffic stop for dog sniff requires reasonable suspicion)
Navarette v. California, 134 S. Ct. 1683 (reasonable suspicion less than probable cause; not a hunch)
United States v. Mendenhall, 446 U.S. 544 (multi‑officer presence not dispositive of seizure)
Whren v. United States, 517 U.S. 806 (selective enforcement challenge governed by Equal Protection, not Fourth Amendment)
United States v. Campa, 234 F.3d 733 (appellate deference to uncontested district court findings on suppression)
United States v. Tiru‑Plaza, 766 F.3d 111 (standard of review for suppression factual findings and legal conclusions)
United States v. Forbes, 181 F.3d 1 (consent analysis under totality of circumstances)