State v. O'Meara

In State v. O'Meara, 198 Ariz. 294, 9 P.3d 325 (2000), prior to the stop, officers had also observed a number of men loitering in front of a store, switching back and forth from one car to another, driving away, and making several U-turns, consistent with the behavior of a narcotics buyer giving his car to the seller to take it to the "stash house" for loading. 198 Ariz. 294, PP2-4, 11, 9 P.3d at 326-27. After stopping one of the cars for speeding, officers noticed a strong odor of fabric softener coming from the trunk, again consistent with the practice of drug traffickers who use such products to mask the odor of drugs. Id. P4. The court concluded that "looking at the whole picture in this case, the car switching, the U-turns, and the fabric softener, there is no doubt that the officer had reasonable suspicion to detain O'Meara while they were waiting for the drug detection dog." Id. P11.