K-9 Alert Not Sufficient to Search Occupants. State v. Wallace.

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Brief Brief.  State v. Wallace, 372 Md. 137 (2002).

QUOTE:  “A canine alert on the exterior of a vehicle does not support the proposition that the drugs potentially in the car are concealed on a particular occupant of that vehicle.  When the police get all of the occupants out of the vehicle and find no drugs in the vehicle, they cannot use a positive general canine scan of the car as authority to go further and search a non-owner/non-driver passenger.” Id. at 159-60.

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