Phippen v. State
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Defendant conditionally pleaded guilty to possession with intent to deliver marijuana. On appeal, Defendant challenged the district court's denial of his motion to suppress evidence discovered during a search of his vehicle. Defendant argued that because the drug dog sniff was inconclusive, the subsequent search of his vehicle was illegal. The Supreme Court affirmed, holding that the totality of the circumstances was sufficient to find probable clause, as additional facts beyond the dog search were used by the district court to determine that probable cause existed, and an officer of reasonable prudence would have been warranted in the belief that controlled substances would be found in Defendant's vehicle.
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