United States v. Kelvin R. Lyons, United States of America v. Michael C. Elma

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• ruling officers did not have affirmative duty to close windows opened by defendant in preparation for dog sniff and noting absence of contrary authority
• finding that an officer developed reasonable suspicion during a traffic stop based on the defendant’s “unusual itinerary,” “contradictory descriptions,” and “amount of luggage”
• holding a drug dog sticking his head through an open window was not a search because the dog did so “on his own” and “was not directed” to do so
• upholding a district court’s finding that the dog would have inevitably smelled the odor of drugs
• approving a 31-minute delay for drug dog to arrive because of reasonable suspicion that drugs were in the vehicle
• finding no Fourth Amendment violation where K9 stuck its head through a van’s open window without being directed to do so by officers

Source: CourtListener parenthetical corpus (CC0).