United States v. Bowman, No. 16-4848 (4th Cir. 2018)Annotate this Case
The Fourth Circuit vacated defendant's conviction for possession with intent to distribute methamphetamine and remanded for further proceedings. On appeal, defendant challenged the district court's denial of his motion to suppress evidence recovered from a dog sniff conducted after an already-completed traffic stop. The court held that the police officer had neither defendant's consent to extend the traffic stop nor a reasonable, articulable suspicion of ongoing criminal activity to justify doing so. Consequently, the prolonged traffic stop abridged defendant's right under the Fourth Amendment to be free of unreasonable seizures.