United States v. Simpson

Christopher Wayne Simpson challenges the denial of his motion to suppress narcotics found in his vehicle, asserting that a state trooper lacked reasonable suspicion to detain him past the legitimate ending point of a traffic stop. Although a close call, we hold that the continued detention was justified because the trooper had reasonable suspicion that Mr. Simpson was engaged in illegal conduct. Mr. Simpsons prior criminal conviction for drug trafficking, his extreme nervousness, and the fact that he provided inconsistent and evasive answers to queries about his travel plans together provided reasonable suspicion to justify extending a legitimate traffic stop to allow further questioning and a canine sniff of his automobile. Accordingly, the district court appropriately denied Mr. Simpsons motion to suppress.