Ward v. Commonwealth, 345 S.W.3d 249

Ward entered a conditional guilty plea to first-degree possession of methamphetamine and second-degree persistent felony offender after a suppression motion was denied.
On January 10, 2010, Officer Mahan stopped Ward's vehicle for a stop-sign violation and ran the license plate.
Ward provided only his social security number; he did not have a license, and no warrants were found after the check.
During the stop, Ward and Garner acted nervous and evasive; Ward did not consent to a search and claimed he had possessed the vehicle 10–11 hours.
A canine unit sniffed the exterior of the vehicle; the dog alerted three times on the passenger side, leading to a search and discovery of methamphetamine in a cigarette pack.
Ward was read Miranda rights and arrested about 33 minutes after the initial stop; he later claimed the drugs belonged to him, not Garner.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the dog sniff during a lawful stop unreasonably extended the stop	Ward	Ward	No; stop was not unreasonably extended

Wilson v. Commonwealth, 37 S.W.3d 745 (Ky. 2001) (probable cause to stop for civil violation; authority to detain)
Epps v. Commonwealth, 295 S.W.3d 807 (Ky. 2009) (dog sniff during stop; duration analyzed for reasonableness)
Prouse, 440 U.S. 648 (1979) (random checks during traffic stops permissible)
Whren v. United States, 517 U.S. 806 (1996) (traffic stops based on probable cause; scope of investigation)
Peyton v. Commonwealth, 253 S.W.3d 504 (Ky. 2008) (standard for reviewing suppression findings)
Meghoo v. Commonwealth, 245 S.W.3d 752 (Ky. 2008) (scope of police inquiry during traffic stop)
Owens v. Commonwealth, 291 S.W.3d 704 (Ky. 2009) (allowing warrant checks and related inquiries during stop)
Delaware v. Prouse, 440 U.S. 648 (1979) (vehicle stops require reasonable suspicion or probable cause)