Cited by

at 365; (stating that an expansion of the scope of a stop “not strictly tied to the circumstances that rendered the initiation of the stop permissible must be supported by at least a reasonable suspicion of additional illegal activity”).

at 365; d 346, 350 (Minn. 2012) (stating that an expansion of the scope of a stop “not strictly tied to the circumstances that rendered the initiation of the stop permissible must be supported by at least a reasonable suspicion of additional illegal activity”).

d 346, 350 (Minn. 2012).

at 365; d 346, 350 (Minn. 2012) (stating that an expansion of the scope of a stop “not strictly tied to the circumstances that rendered the initiation of the stop permissible must be supported by at least a reasonable suspicion of additional illegal activity”).

“[E]xpand[ing] the duration or scope of the stop beyond the stop’s original justification” does not violate the Fourth Amendment or article I, section 10 of the Minnesota Constitution if “the officers had reasonable, articulable suspicion to support that expansion.” see Terry, 392 U.S. at 18-19.

One of the legal conclusions reviewed de novo is “a district court’s determination of reasonable suspicion of illegal activity.”

Under article I, section 10 of the Minnesota Constitution, any expansion of the scope of the stop “not strictly tied to the circumstances that rendered the initiation of the stop permissible must be supported by at least a reasonable suspicion of additional illegal activity.” (citing State v. Askerooth, 8 -65 (Minn. 2004)); (explaining that “[e]xpansion of the scope of the stop to include investigation of other suspected illegal activity” requires “reasonable, articulable suspicion of such

“Evidence resulting from an unreasonable seizure must be exclud ed.”

-52 (Minn. 2012) ( stating that “the basis of the officer’s suspicion must satisfy an objective, totality-of-the-circumstances test” that considers whether “the facts available to the officer at the moment of the seizure would warrant a [person]of reasonable caution in the belief that the action taken was appr

And “even a single question, depending on its content, could expand the scope of a traffic stop[.]” n.1 (Minn. 2012).

“We review de novo a district court’s determination of reasonable suspicion of illegal activity.”

In response, the state cites only one precedential opinion in support of its argument that the warrantless search was supported by probable cause: d 346 (Minn. 2012).

nd justified by the circumstances which rendered the initiation of the stop permissible[,]” and “each step of an officer’s investigation must be tied to and justified by one of the following: (1) the original legitimate purpose of the stop, (2) independent probable cause, or (3) reasonableness, as defined in Terry[ v. Ohio, 392 U.S. 1 (1968)].” (quotations omitted)); n.1 (Minn. 2012) (“recogniz[ing] that even a single question, depending on its content, could expand the scope of a traffic stop”)

(“When considering whether a traffic stop violated a person’s right to be free from unreasonable searches and seizures .

Additionally, appellate courts have noted that “by virtue of the special training they receive, police officers articulating a reasonable suspicion may make inferences and deductions that might well elude an untrained person.” (- 52 (Minn. 2007)).

“We review de novo a district court’s determination of reasonable suspicion.”

-54 (Minn. 2012) (acknowledging the court’s reluctance to consider nervous behavior as evidence of criminal activity but concluding that Smith’s “violent shaking” and “evasive” explanation as to why he was shaking provided the police officer with reasonable, articulable suspicion that Smith was engaged in othe

“We review de novo a district court’s determination of reasonable suspicion.”

An intrusion not strictly tied to the circumstances that made the initial stop permissible must be supported by “at least a reasonable suspicion of additional illegal activity.” State v. Smith

Where police action expanded the scope of a stop, a court must consider “whether the officers had reasonable, articulable suspicion to support that expansion.”

An intrusion not strictly tied to the circumstances that made the initial stop permissible must be supp orted by “at least a reasonable suspicion of additional illegal activity.”

Under the Minnesota Constitution, an intrusion not stric tly tied to the circumstances that made the initial stop permissible must be supported by “at least a reasonable suspicion of additional illegal activity.”

(1) the original legitimate purpose of the stop, (2) independent probable cause, or (3) reasonableness, as defined in Terry.” (quoting Askerooth, d at 365).

Compare State v. Smith , –52 (Minn. 2012) (relying on evasive answers, lack of proof of insurance, and other facts to justify expansion of search for controlled substances or weapons), and Flowers, d at 251–52 (concluding that failure to comply with directions to pull over and suspicious movements in vehicle 14 conduct as “

Under the Minnesota Constitution, an intrusion not strictly tied to the circumstances that made the initial stop permissible must be supported by “at least a reasonable suspicion of additional illegal activity.”

Absent independent probable cause, when a police officer expands the scope of a traffic stop beyond the initial justifica tion for the stop, the officer must have reasonable suspicion of “additional illegal activity.” d 346, 350 (Minn. 2012).

And “ordinary drivers may become nervous during a routine traffic stop.” State v. Smith