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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

d 346, 350 (Minn. 2012).

Under our constitution, a police officer cannot expand the scope of a traffic stop beyond the original purpose of the stop without “at least a reasonable suspicion of additional criminal activity.” d 346, 350 (Minn. 2012); see also Minn. Const. art. I, § 10 (prohibiting unreasonable searches); (holding that “Article I, Section 10 of the Minnesota Constitution requires that each incremental intrusion during a traffic stop be tied to and justified by one of the fo

When determining whether an officer had a reasonable, articulable suspicion, we use an “objective, totality -of-the-circumstances test,” which asks “whether the facts available to the officer at the moment of the [search] would warrant a man of reasonable caution in the belief that the action taken was appropriate.” State v. Smith , d 346, 351–52 (Minn. 2012) (quotations omitted).

When reviewing a district court’s suppression order, we “accept the district court’ s factual findings unless they are clearly erroneous” and “review de novo a district court’s determination of reasonable suspicion of illegal activity.” .

Terry v. Ohio , 392 U.S. 1, 18, 88 S. Ct. 1868, 1878 (1968); State v. Smith

When reviewing a district court’s pretrial-suppression ruling, we “accept the district court’s factual findings unless they are clearly erroneous” and “review de novo a district court’s determination of reasonable suspicion of illegal activity .”

(explaining that nervousness may be validly considered alongside the other relevant circumstances to justify a search or seizure).

Under the Minnesota Constitution, “an intrusion 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.”

An expansion 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.”

When articulating reasonable suspicion, police officers may rely on their specialized training to “make inferences and deductions that might well elude an untrained person.”

But this position is contrary to well - established caselaw which directs Minnesota courts to determine whether reasonable suspicion exists by considering the “totality of the circumstances.” -52 (Minn. 2012) (“To be reasonable, the basis of the officer’s suspicion must satisfy an objective, totality-of-the-circumstances test.”).

In State v. Smith, officers stopped defendant for traffic violations and one of them noticed defendant “was shaking very violently—way worse than anyone with Parkinson’s disease.” -49 (Minn. 2012) (quotations omitted).

Thus, each incremental step in an expanded detention 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.’” (quoting Askerooth, d at 365).

Put another way, we must decide “whether the officer[] expanded the duration or scope of the stop beyond the stop’s original justification.”

articulate reasonable grounds for believing that drugs may be present in the place they seek” to search; and (2) the police must be “lawfully present in the place where the canine sniff is conducted.” 2 An officer’s suspicion meets the reasonable, articulable standard based on an “objective, totality-of-the-circumstances test.”

A stop is valid so long as “each incremental intrusion” is “strictly tied to and justified by the circumstances which rendered the initiation of the stop permissible.” (quotation omitted).

Under the Minnesota Constitution, “an intrusion 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.”

Under the Minnesota Constitution, “an intrusion 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.”

In assessing reasonable suspicion , we consider the totality of the circumstances known to the officer at the time of the seizure, State v. Smith , 51-52 (Minn. 2012), including “s eemingly innocent factors ,” State v. Davis

In determining whether an officer had reasonable articulable suspicion to stop a defendant, “the officer’s suspicion must satisfy an objective, totality-of-the-circumstances test.”

“[A]n intrusion not strictly tied to the c ircumstances that rendered the initiation of the stop permissible must be supported by at least a reasonable suspicion of additional illegal activity.”

An investigative stop remain s valid when “each incremental intrusion during a stop is strictly tied to and justified by the circumstances which rendered the initiation of the stop permissible.” (quotation omitted).

“Reasonable suspicion must be particularized and based on specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” (quotations omitted).

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

“A traffic stop does not violate the right to be free from unreasonable searches and seizures as long as each incremental intrusion during a stop is strictly tied to and justified by the circumstances which rendered the initiation of the stop permissible.” (quotations omitted).

State v. Smith - 352 (Minn. 2012).

“To remain constitut ional, an intrusion 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.”