State v. Valenzuela-Pena

Citations

• 2019 Ohio 1701

Syllabus

Temporary removal of a package from a FedEx truck for purposes of a canine drug sniff was not a seizure under the Fourth Amendment. Circumstances surrounding the delivery of a second package to an out-of-state couple during their brief, two-day stay at a bed-and-breakfast provided reasonable suspicion that the package contained contraband and justified the brief, non-invasive investigatory detention of the package.