Just a week after the United States Supreme Court suppressed evidence discovered as a result of an dog sniff because police unjustifiably prolonged a traffic stop in Rodriguez v. United States, 575 U.S. _ (Apr. 21, 2014) (see my April 26, 2015 blog post), the PA superior Court in Commonwealth v. Nguyen, 2015 PA Super. 98 (Apr. 27, 2015) held that a consensual car search was illegal when it was conducted after the conclusion of a traffic stop when officers re-engaged the defendant.
There’s no word yet whether the Commonwealth will seek review in front of the PA Supreme Court. To read a PDF of Nguyen, click here.
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