This unusual itinerary, coupled with the large sum of cash, and other factors, support the trial court’s finding of reasonable suspicion. See United States v. Digiovanni, 650 F.3d 498, 513 (4th Cir. 2011) (noting an unusual travel itinerary, “coupled with other compelling suspicious behavior,” supports a finding of reasonable suspicion); cf. United States v. Brugal, 209 F.3d 353, 361 (4th Cir. 2000) (“[A] reasonable officer could conclude that few innocent travelers from New York City are traveling northbound on Interstate 95 in South Carolina at 3:30 a.m. in a vehicle rented in Miami fourteen hours earlier.”).
The defendant’s consent to search the vehicle was the product of the illegal detention.United States v. Digiovanni, 650 F.3d 498 (4th Cir. 2011)The defendant was pulled over based on a traffic violation. Yet, the police spent the first fifteen minutes of the stop talking about drugs and the defendant’s itinerary and did nothing to pursue the typical traffic violation procedures.
The resulting frisk was the product of this illegal detention.United States v. Digiovanni, 650 F.3d 498 (4th Cir. 2011)The defendant was pulled over based on a traffic violation. Yet, the police spent the first fifteen minutes of the stop talking about drugs and the defendant’s itinerary and did nothing to pursue the typical traffic violation procedures.