Messy Vehicle Interior Doesn’t Justify Extended Police Traffic Stop and K9 Search.

Mr. Luis Alfonso Leon was stopped by law enforcement after he was observed illegally driving in a passing lane. During the traffic stop, the officer began to suspect Mr. Leon was trafficking drugs. A search of his vehicle uncovered seventy-six pounds of methamphetamine, and Mr. Leon was charged with one count of possessing methamphetamine with intent to distribute. Following a failed motion to suppress, he pled guilty and was sentenced to seventy months’ imprisonment. On appeal, Mr. Leon challenges the denial of his suppression motion, arguing that the officer lacked reasonable suspicion to extend the stop and investigate the suspected drug trafficking. We agree and therefore reverse.

Takeaways:
1. the fact that the defendant was coming from Phoenix when he was stopped near Denver did not provide reasonable suspicion for prolonging the traffic stop;
2. The defendant‘s travel plans of driving from Denver to pick up religious books and perhaps stay for an event were not so implausible as to provide reasonable suspicion for prolonging traffic stop;
3. The condition of the vehicle’s interior did not provide reasonable suspicion of criminal activity;
4. The defendant’s alleged nervousness during the traffic stop was not extreme and bore negligible weight in determining whether the trooper had reasonable suspicion for prolonging traffic stop; and
5. The trooper’s belief that the defendant was traveling in a third-party vehicle did not provide reasonable suspicion.

Full case here: https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010110916595.pdf