State of Florida v. Joshua Lyle Creller

Summary

The court held that an officer may order a driver to exit a vehicle for officer-safety reasons when a K-9 officer arrives during an ongoing, lawful traffic stop and intends to conduct an exterior dog sniff. Because the exit command occurred before the traffic citation was issued and did not prolong the stop, the court concluded that the rule governing officer-safety exit orders applied and that the rule governing prolongation of traffic stops did not. The court quashed the district court's decision and approved the conflicting decision. No separate opinion is included in the record provided.