U.S. v. Devalois

Defendant was found guilty of illegally possessing a firearm as a felon and appealed, arguing that the district court erred when it denied his motion to suppress because law enforcement unconstitutionally prolonged a traffic stop to conduct a dog sniff. The Seventh Circuit affirmed, finding that the district court’s conclusion that the officer did not prolong the traffic stop in order to conduct a dog sniff was not clearly erroneous where the evidence supported that the length of the stop was dictated by “diligence and not delay” and, as a result, the discovery of the firearm was made pursuant to a lawful search and seizure. (SYKES and ST. EVE, concurring)