US v. Teresa Miller, No. 21-4086 (4th Cir. 2022)
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Defendant was indicted on one count of unlawfully possessing a firearm. The firearms at issue were uncovered during a traffic stop. Defendant was traveling in the backseat of a vehicle when the vehicle was stopped by the officer for having an inoperable taillight. After printing a warning citation for the driver, the officer used his canine to sniff around the vehicle and then conducted a full search when the dog alerted, uncovering two firearms in Defendant’s backpack. The district court denied Defendant’s motion to suppress evidence of the firearms, concluding that the officer had reasonable suspicion to extend the stop and conduct the search.
On appeal, Defendant argued that the district court erred by (1) denying her motion to transfer the proceedings to another district pursuant to Federal Rule of Criminal Procedure 21(a) and (2) finding that the officer had reasonable suspicion to extend the traffic stop.
The Fourth Circuit reversed the district court’s order denying Defendant’s motion to suppress, vacated Defendant’s conviction and sentence, and remanded to the district court. The court held that (1) Defendant’s motion to transfer was appropriately denied and (2) the officer lacked a reasonable, articulable factual basis for extending the traffic stop to conduct the dog sniff.
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