State of Iowa v. Stephen Andrew Arrieta

Summary

The court held that officers unlawfully prolonged Arrieta’s valid commercial-vehicle inspection to await a drug dog after the inspection could reasonably have been completed. The State failed to establish that the remaining paperwork review justified the twenty-five-minute delay, and the circumstances did not provide reasonable suspicion to extend the detention for an unrelated drug investigation. The court therefore suppressed the resulting evidence and reversed and remanded.