During a lawful traffic stop, a K-9 officer asked Creller multiple times to exit his vehicle for officer safety, while he and his dog conducted a sniff search around Creller’s car. Creller refused to comply and was ultimately arrested for resisting an officer with violence. Officers searched Creller incident to his arrest and found drugs on him. Creller filed a motion in the trial court to suppress the drugs, arguing that the K-9 officer’s exit command was an unreasonable seizure under the Fourth Amendment. The trial court denied the motion, a jury convicted Creller, and he appealed.  The Second District reversed the trial court’s decision and certified conflict with another appellate court decision. This Court accepted review to address the certified conflict between the decisions.

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