State Of Louisiana v. Keron D. Landry

STATE OF LOUISIANA

COURT OF APPEAL, FIRST CIRCUIT

STATE OF LOUISIANA NO. 2023 KW 0462

VERSUS

KERON D. LANDRY MAY 17, 2023

In Re: Keron D. Landry, applying for supervisory writs, 23rd
Judicial District Court, Parish of Ascension, No.
46260.

BEFORE: GUIDRY, C. J., WOLFE AND MILLER, JJ.

WRIT GRANTED. The traffic stop, detention, and search of

relator' s trailer and vehicle were captured on the investigating
officer' s body camera. The video is the best evidence of what

occurred during this incident. The totality of the

circumstances
existing at the time of the stop did not create

reasonable suspicion of a drug crime or any other criminal

activity. See United States v. Cortez, 449 U. S. 411, 417- 18,
101 S. Ct. 690, 66 L. Ed. 2d 621 ( 1981). Absent reasonable

suspicion of additional criminal activity, waiting for or

conducting a dog sniff cannot prolong a stop justified by only a
traffic violation beyond the amount of time reasonably required
to complete the mission of issuing a traffic ticket and

attending to related safety concerns. See Rodriguez v. United
States, 575 U. S. 348, 135 S. Ct. 1609, 191 L. Ed. 2d 492 ( 2015).
Therefore, the district court abused its discretion in denying
the motion to suppress. Accordingly, the district court' s

ruling is reversed, the motion is granted, and this matter is
remanded for further proceedings.

JMG
EW
SMM

COURT OF APPEAL, FIRST CIRCUIT

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