Illinois Appellate Court
Criminal Court
Motions to Suppress
Court properly found that traffic stop was unreasonably prolonged prior to canine alert, and thus properly granted motion to suppress crack cocaine located in vehicle trunk.Officer unlawfully prolonged duration of investigative stop when he interrupted his traffic citation prepartion to conduct a free-air canine sniff based on unparticularized suspicion of criminal activity. Officer's deviation from purpose of stop to conduct drug investigation was not supported by independent reasonable suspicion and thus unlawfully prolonged duration of stop.(CARTER and O'BRIEN, concurring.)