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Search & Seizure – Consensual Encounter – Calling Drug Dog

Police who initially saw defendant urinating near a car during the early morning hours at a known drug-dealing location in Virginia Beach violated defendant’s Fourth Amendment rights when, without a reasonable articulable suspicion, an officer told defendant he had called a drug dog to “run your car,” and the Court of Appeals reverses defendant’s marijuana conviction.
Middlebrooks v. Commonwealth (Va.Ct.App.) (VLW 008-7-361) (10 pp.)

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