40-minute Detention OK for Traffic Stop

U.S. v. Douglas, 2006 WL 2642129 (9/15/06)(unpub'd) - The 40 minutes it took to verify the validity of the defendant's license was okay, even though the delay was caused by the dispatch people looking for his license in the state of Washington, rather than the Washington, D.C., database. During that extra time, the officer developed reasonable suspicion to detain (including based on the defendant's increasingly confrontational manner). The 10th seemed untroubled by the officer's testimony that he almost always detains people in order to use a drug dog whenever they refuse consent to search.