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United States Court of Appeals for the Fourth Circuit
65 F. 3d 1241
Published/Precedential
October 4, 1995
Consensual encounter turned into an investigative detention when train passenger refused consent search of carry-on luggage and officers told her that they were seizing her bag for a canine sniff.
An investigative detention must be supported by reasonable and articulable suspicion.
Drug courier profile, without more, does not create reasonable suspicion.
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