United States v. Terrence Vaughan, 2012 U.S. App. LEXIS 24591

Vaughan and Scott were stopped for speeding on I-95 by Virginia State Police officer Homiak.
Four cell phones (two prepaid) were in the center console; Homiak associated prepaid phones with drug activity.
Scott appeared highly nervous; Vaughan provided travel details with some inconsistencies.
Homiak separated occupants, questioned Scott, and observed conflicting travel narratives that increased suspicion.
A drug-detection dog was requested and arrived during the stop; dog alerted near the trunk, leading to a search revealing 830.6 grams of cocaine and a handgun.
Vaughan moved to suppress evidence; district court denied; Vaughan pled guilty while reserving appellate rights; Fourth Circuit affirmed denial of suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there reasonable suspicion to extend the stop?	Vaughan argues no reasonable suspicion to prolong.	Homiak had reasonable suspicion from nervousness, phones, and conflicting stories.	Yes; suspicion existed and justified a brief extension.

Whren v. United States, 517 U.S. 806 (1996) (temporary traffic stops may be seizures subject to Terry analysis)
Illinois v. Wardlow, 528 U.S. 119 (2000) (nervous, evasive behavior contributes to suspicion in traffic stops)
United States v. Guijon-Ortiz, 660 F.3d 757 (4th Cir. 2011) (frames of investigative detention and scope/duration limits)
Arizona v. Johnson, 555 U.S. 323 (2009) (may ask questions and take actions that do not prolong the stop)