State v. Cooper

Citations

• 2026 ND 68

Syllabus

An officer must administer the Miranda warning when a person is subject to custodial interrogation. A suspect is in custody when there is a formal arrest or restraint on the suspect's freedom of movement to the degree associated with a formal arrest. The \automobile exception\ to the Fourth Amendment's warrant requirement allows law enforcement officers to search a vehicle for illegal contraband without a warrant upon establishing probable cause the vehicle contains contraband. Allowing a drug-sniffing dog to sniff a vehicle is not a search within the meaning of the Fourth Amendment. A drug-sniffing dog indicating the presence of a controlled substance establishes probable cause. Unrelated inquiries are permitted during a stop as long as they do not prolong the stop and extend the time the individual is detained. A stop may be prolonged only if the officer has reasonable suspicion to justify detaining the individual for inquiries unrelated to the stop.