Illinois V. Caballes - Facts

Facts

An Illinois state trooper stopped Roy Caballes for speeding on an interstate highway. When the trooper reported the stop to his headquarters, a member of the state police's drug interdiction squad overheard the report and proceeded to the location of the stop. When the drug officer arrived, Caballes was in the trooper's car while the trooper was writing out a warning ticket. The drug officer walked his drug-sniffing dog around Caballes' car, and the dog alerted at the trunk. Inside the trunk, the officers found marijuana. The whole episode lasted less than 10 minutes.

After unsuccessfully moving to suppress the marijuana before trial, Caballes was convicted of narcotics trafficking and sentenced to 12 years in prison and a $256,136 fine. The trial judge denied Caballes' motion to suppress, reasoning that the officers had not unnecessarily prolonged the traffic stop, and the indication by the dog, of narcotics in the vehicle, gave them probable cause to search the trunk of Caballes' car. The Appellate Court of Illinois affirmed, but the Illinois Supreme Court reversed, holding that because the dog sniff was performed without reference to specific and articulable facts, it unjustifiably enlarged the scope of the stop into a drug investigation. The Supreme Court agreed to hear the case in order to answer the question of whether the Fourth Amendment requires reasonable suspicion to justify using a drug-sniffing dog during a routine and otherwise legitimate traffic stop.

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