Montana Supreme Court

State v. C. Loberg

August 27, 2024418 Mont. 38

Summary

The court held that the officer lacked particularized suspicion to detain Loberg and conduct a canine sniff of his vehicle after the traffic stop had ended. The circumstances relied on—pinpoint pupils, a single air freshener, leaving a casino, an inconsistent explanation, stale uncorroborated reports, and the brief delay in stopping—amounted only to generalized suspicion or an inarticulable hunch. The court therefore reversed the order denying suppression and required suppression of the evidence.