State v. Allen

I write because I respectfully disagree with the majority opinion. In this case, it is clear that the officer had effectively completed his traffic investigation prior to deploying his drug dog and, as such, his search of the vehicle was unlawful.

A seizure justified only by a police-observed traffic violation ‘become [s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission” of issuing a ticket for the violation. Rodriguez v. United States, _U. S.__(II) (135 SCt 1609, 191 LE2d 492) (2015). The United States Supreme Court has noted that the incidental…