People v. Tyus

Defendant was convicted of controlled substance trafficking and criminal drug conspiracy, after package shipped via UPS was searched, pursuant to search warrant, and found to contain cocaine. Police were aware of multiple factors in support of their suspicion that package contained narcotics, including that package was heavily taped around all edges and seams, which evinced effort to defeat canine detection. Additional factors, such as false names listed and telephone numbers on package, and method of shipping (next day air, early morning delivery) continued to bear weight even after dog failed to alert. Thus, facts were sufficient to establish reasonable, articulable suspicion that package contained narcotics. (McCULLOUGH and COOK, concurring.)