Washington v. Estes (Majority and Concurrence)Annotate this Case
During an investigatory stop of a vehicle, a traffic violator can be temporarily detained until the legitimate investigative purposes of the traffic stop have been completed. Michael Phelps appealed a criminal judgment entered after he conditionally pleaded guilty to possession of methamphetamine with intent to deliver after the district court denied his motion to suppress evidence. Phelps argued the district court erred in denying his motion to suppress evidence because the traffic stop was not supported by reasonable suspicion and the dog sniff unreasonably extended the traffic stop. The North Dakota Supreme Court concluded: (1) the district court did not err in finding the officer had reasonable suspicion to initiate a traffic stop; and (2) the dog sniff conducted on Phelps' vehicle did not require independent reasonable suspicion because it occurred contemporaneously to the completion of duties related to the initial traffic stop.