State v. J. McElroy

Summary

The Court held that the trooper unlawfully prolonged a completed traffic stop and DUI investigation to pursue a drug-possession investigation and conduct a canine sniff without new, particularized suspicion that the vehicle contained drugs. The odor of marijuana, nervousness, travel indicators, inconsistent accounts, and use of a third-party vehicle did not provide sufficient additional objective suspicion under the totality of the circumstances. The suppression ruling and resulting conviction and sentence were reversed and the matter was remanded.