Unrelated Drug Questioning During Ongoing Traffic Stops Permissible if It Does Not Prolong the Stop: Commentary on Randall Bays v. Commonwealth of Kentucky

I. Introduction

This commentary examines the Supreme Court of Kentucky’s unpublished memorandum decision in Randall Bays v. Commonwealth of Kentucky, 2024-SC-0340-MR (rendered Dec. 18, 2025), affirming a Knox Circuit Court judgment that convicted Bays of first-degree trafficking in a controlled substance (methamphetamine, two or more grams, first offense) and of being a first-degree persistent felony offender (PFO 1).

The opinion is explicitly designated “NOT TO BE PUBLISHED” under RAP 40(D), meaning it is not binding precedent and may not be cited as such in Kentucky courts. Nonetheless, post-2003 unpublished decisions may be cited for consideration where no published opinion adequately addresses the issue; thus, this case holds potential persuasive value, particularly in the highly active area of Fourth Amendment traffic-stop jurisprudence.

The core issue before the Court was whether police officers unconstitutionally prolonged a traffic stop—initiated for careless driving—by questioning Bays about drugs, seeking consent to search, and eventually employing a drug-detection dog, all without a warrant. Bays claimed the stop was improperly extended in violation of the Fourth Amendment and that the resulting evidence (over two pounds of methamphetamine) should have been suppressed.

The Court, applying federal Fourth Amendment doctrine and Kentucky’s own line of traffic-stop cases, affirms the denial of the motion to suppress. The decision clarifies several important points:

How deference to a trial court’s fact-finding operates when officer testimony is inconsistent.
The difference between “forfeited” and “waived” claims—especially when defense counsel concedes certain points in the trial court.
How “unrelated” questions about drugs and requests for consent can be lawful if asked while the officer is still carrying out the legitimate “mission” of the traffic stop and do not measurably extend its duration.
How consent, combined with a canine sniff and observable conduct by a passenger, can yield probable cause for a full vehicle search.

II. Summary of the Opinion

A. Factual Background

A confidential informant (CI) told Barbourville Police Detective Adam Townsley that Randall Bays would be driving from Louisville to Knox County with methamphetamine, describing the vehicle (gold Buick LeSabre) and giving a license plate number (BTX-241) and general information about passengers. Later that day, Officer Karl Middleton saw a gold LeSabre with a very similar plate (BTX-231) driven by Bays, with a single female passenger, later identified as Stacie Goley.

Officer Middleton followed and observed Bays cross the center line multiple times. He initiated a traffic stop, citing careless driving. Bays explained he was trying to turn off cruise control, and he failed to produce valid proof of insurance. Middleton asked if there were any illegal substances in the car; Bays said no. Middleton then had Bays exit the vehicle to perform field sobriety tests (FSTs) and requested consent to search the vehicle, which Bays granted.

Within about ten minutes of the initial stop, a K-9 unit arrived. Goley exited the car and was observed throwing a small bag of suspected methamphetamine to the ground. The K-9 conducted a “free air sniff” around the car and alerted on the driver’s side door. Officers then searched the vehicle and found over two pounds of suspected methamphetamine in coffee cans in the trunk. Around forty-five minutes elapsed from the initial stop to the arrests.

Bays was indicted for trafficking in a controlled substance (meth, ≥ 2 grams), failure to produce insurance, careless driving, and PFO 1. He moved to suppress the evidence from the warrantless search. After a suppression hearing at which Officer Middleton was the only witness and no body camera footage was available, the trial court denied the motion. The Commonwealth later dismissed the traffic infractions, and a jury convicted Bays of trafficking and PFO 1, recommending a total sentence of twenty years, which the trial court imposed.

B. Issues on Appeal

Bays raised a single overarching claim: the police unlawfully extended the traffic stop beyond its permissible scope in violation of the Fourth Amendment. Specifically:

He argued that the “mission” of the traffic stop was not diligently pursued because there was no basis to require FSTs.
He argued that the officer lacked reasonable and articulable suspicion to investigate drugs at the outset of the stop.

Critically, Bays conceded these specific arguments were not preserved below and sought palpable error review under RCr 10.26. Moreover, at the suppression stage he had affirmatively conceded that FSTs were a lawful part of the traffic stop’s purpose, framing his earlier argument around when the initial mission ended—not whether the FSTs were justified in the first place.

C. Holding

The Supreme Court of Kentucky affirmed the judgment, holding:

The trial court’s factual findings—including that Bays’ driving was “erratic” and that consent to search was given when Bays exited the vehicle before FSTs—were supported by substantial evidence and thus binding on appeal.
Bays waived (rather than merely forfeited) any challenge to the propriety of the FSTs by expressly conceding in the trial court that the FSTs were part of the lawful mission of the stop; therefore, he could not reverse course on appeal.
The officer’s questions about drugs and his request for consent to search were “unrelated” to the traffic violation but did not prolong the stop because they occurred concurrently with the officer’s legitimate investigation into careless driving (i.e., the FSTs).
An officer may ask such unrelated questions and request consent during an otherwise lawful stop, so long as those actions do not measurably extend the stop’s duration.
The canine sniff of the vehicle’s exterior, the passenger’s attempt to discard suspected methamphetamine, and the resulting alert gave rise to probable cause for a warrantless search of the trunk under Meghoo v. Commonwealth.
Because the consent and canine sniff were valid and did not flow from an unlawful prolongation, the motion to suppress was properly denied.

Having resolved the case on these grounds, the Court declined to decide whether the CI’s tip alone created independent reasonable suspicion to justify a drug investigation.

III. Analysis

A. Standard of Review and Palpable Error

The Court begins by reiterating the familiar two-tiered standard for reviewing suppression rulings:

Fact-finding: The appellate court asks whether the trial court’s findings of fact are supported by substantial evidence. If so, they are “conclusive.” The Court cites Payne v. Commonwealth, 681 S.W.3d 1 (Ky. 2023), and Commonwealth v. Neal, 84 S.W.3d 920 (Ky. App. 2002).
Legal conclusions: The appellate court reviews de novo the trial court’s application of law to those facts.

Because Bays did not preserve his key Fourth Amendment arguments, he invoked palpable error review under RCr 10.26. The Court quotes the rule:

A palpable error which affects the substantial rights of a party may be considered ... even though insufficiently raised or preserved for review, and appropriate relief may be granted upon a determination that manifest injustice has resulted from the error.

The Court, citing Brewer v. Commonwealth, 206 S.W.3d 343 (Ky. 2006) and Martin v. Commonwealth, 207 S.W.3d 1 (Ky. 2006), explains that “palpable error” must be:

“Easily perceptible, plain, obvious, and readily noticeable,” and
So serious that it likely changed the outcome or was so fundamental as to threaten due process—“shocking or jurisprudentially intolerable.”

However, as discussed below, the Court ultimately characterizes some of Bays’ appellate theories not as mere forfeiture subject to palpable error review, but as waived claims, which generally cannot be raised at all on appeal.

B. Deference to the Trial Court’s Factual Findings

1. “Erratic driving”

Bays challenged the trial court’s use of the term “erratic” to describe his driving, arguing that Officer Middleton never explicitly used that word in his testimony. The Supreme Court upholds the trial court’s characterization as a reasonable inference from the evidence:

Middleton testified that Bays crossed the center line multiple times.
The Court cites decisions from other jurisdictions describing crossing the center line as “erratic driving” and as sufficient justification for a traffic stop for impaired or unsafe driving.
Importantly, Bays himself—at the trial court level—conceded he was “pulled over for careless driving” and that FSTs were within “the only lawful purpose of the traffic stop in this case.”

The Court invokes Roberson v. Commonwealth, 185 S.W.3d 634 (Ky. 2006), to emphasize that a factfinder may draw reasonable inferences from the evidence. There was thus no basis to disturb the finding that Bays’ driving was “erratic” enough to justify the stop.

2. Conflicting testimony about timing of consent

A more subtle factual dispute involved when Bays consented to the search. Officer Middleton’s testimony varied:

He initially said he requested consent as Bays exited the vehicle.
He also testified at another point that he asked during the FSTs.
Elsewhere, he characterized the request more loosely, as occurring during his investigation of both the traffic stop and the CI tip.

When questioned by the court, Middleton stated he “thought” and “believed” he asked for consent when he ordered Bays out of the vehicle.

The trial court resolved these inconsistencies by finding that consent was given when Bays exited the vehicle and before FSTs were performed. The Supreme Court emphasizes:

Factfinders have authority to weigh inconsistent or conflicting testimony, even from the same witness.
The Court relies on Osborne v. Commonwealth, 718 S.W.3d 622 (Ky. 2025), and Hampton v. Commonwealth, 231 S.W.3d 740 (Ky. 2007), to reinforce that resolving inconsistencies is part of the factfinder’s core role.
Only where a trial court “disregards crucial undisputed testimony” might its factual findings lack substantial evidence, citing Commonwealth v. Conner, 636 S.W.3d 464 (Ky. 2021) and Turley v. Commonwealth, 399 S.W.3d 412 (Ky. 2013). That was not the case here.

Because substantial evidence supported the finding that consent was given at the outset—when Bays was ordered from the vehicle—the Supreme Court treats that as conclusive and proceeds to legal analysis on that factual basis.

C. Waiver vs. Forfeiture: The Concession on Field Sobriety Tests

A central strategic misstep for the defense becomes legally decisive on appeal. In the trial court, Bays argued that the traffic stop’s lawful mission was completed after the FSTs; he did not argue that FSTs themselves were unlawful. Indeed, in his written argument below, he expressly stated:

He was pulled over for careless driving, and Field Sobriety Tests were performed. This was the only lawful purpose of the traffic stop in this case...

On appeal, Bays shifted ground, claiming that there was no basis to require FSTs at all. The Court characterizes this as an attempt to repudiate an earlier concession and invokes:

Gasaway v. Commonwealth, 671 S.W.3d 298 (Ky. 2023), citing United States v. Olano, 507 U.S. 725 (1993), emphasizing that a valid waiver of a known right precludes appellate review, whereas a forfeited claim may receive palpable error review.
Genesis Healthcare Corp. v. Symczyk, 569 U.S. 66 (2013), for the broader principle that a party who concedes a point of law or fact in the trial court generally cannot later argue the contrary on appeal.

Because Bays had affirmatively accepted that the FSTs were within the lawful mission of the stop, the Court treats that issue as waived—not merely unpreserved. As such, the Court refuses to examine whether independent reasonable suspicion was required or present for FSTs; that line of argument is simply off the table.

D. Fourth Amendment Doctrine: Traffic Stops, Mission, and Prolongation

1. Basic principles

The Court restates fundamental Fourth Amendment rules:

The Fourth Amendment protects against unreasonable searches and seizures.
Warrantless searches are per se unreasonable unless an established exception (such as consent, probable cause with automobile exception, etc.) applies, citing Payne v. Commonwealth.
The Commonwealth bears the burden of proving any claimed exception.

Traffic stops are seizures under the Fourth Amendment. The Court, following Davis v. Commonwealth, 484 S.W.3d 288 (Ky. 2016), and Commonwealth v. Bucalo, 422 S.W.3d 253 (Ky. 2013), notes:

Police may initiate a traffic stop if they have probable cause to believe a traffic violation occurred (such as careless driving via center-line crossings).
Subjective motives (e.g., an underlying desire to search for drugs) do not invalidate a stop supported by objective probable cause.
However, once the mission of the traffic stop is complete, further detention requires reasonable and articulable suspicion of criminal activity.

Critically, Kentucky has rejected any “de minimis time” exception for extending a stop: any measurable extension beyond the mission, even brief, must be supported by reasonable suspicion. The Court cites Davis and Turley and reiterates this again through Carlisle v. Commonwealth, 601 S.W.3d 168 (Ky. 2020).

2. The three-part Carlisle test

Following Carlisle, the Court uses a three-part inquiry:

Was the traffic stop still ongoing or had it concluded?
If ongoing, did the officer inquire into matters unrelated to the stop’s mission?
If unrelated matters were explored, did those inquiries prolong the stop?

This framework operationalizes the U.S. Supreme Court’s decision in Rodriguez v. United States, 575 U.S. 348 (2015), which held that officers may not extend a traffic stop—even briefly—to conduct a dog sniff absent reasonable suspicion, unless they are doing so concurrently with other mission-related tasks.

3. Mission of the stop and officer safety

The Court, drawing on Commonwealth v. Clayborne, 635 S.W.3d 818 (Ky. 2021) and Rodriguez, distinguishes:

Mission-related acts: checking license, registration, insurance; running warrant checks; issuing a citation; performing FSTs when justified; and addressing officer safety concerns.
Unrelated criminal investigation: drug investigations (e.g., dog sniffs) which are not inherent to enforcing traffic laws.

The Court notes that safety-based actions (ordering a driver out of the car, checking for weapons, etc.) are closely tied to the mission because traffic stops inherently pose some risk to officers. It cites Carlisle for the proposition that ordering a driver to exit is permissible as a matter of course.

4. Unrelated investigation and “concurrent operations”

Importantly, the Court emphasizes that officers can conduct unrelated investigations during a traffic stop “so long as those inquiries do not measurably extend the duration of the stop,” citing Arizona v. Johnson, 555 U.S. 323 (2009), and Muehler v. Mena, 544 U.S. 93 (2005), which build on Florida v. Bostick, 501 U.S. 429 (1991).

Kentucky has developed a “concurrent operations” concept through Clayborne and Commonwealth v. Mitchell, 610 S.W.3d 263 (Ky. 2020):

When it comes to pursuing unrelated investigative issues, officers must be able to do so while simultaneously completing the purpose of the stop.

That is, if the officer can carry out both the traffic mission and the unrelated investigation at the same time, and no extra time is added, the Fourth Amendment is not violated despite the lack of separate reasonable suspicion for the unrelated investigation.

E. The New Clarification: Unrelated Drug Questioning and Consent During an Ongoing Stop

1. Are drug questions “related” to a traffic stop?

In Carlisle, the Kentucky Supreme Court left unresolved whether questioning a driver about drugs is itself “unrelated” to a traffic stop’s mission. In this case, the Court squarely addresses it.

The Court notes that:

Officer Middleton testified that investigating the CI’s tip about drugs was the “main reason” for the stop.
He asked Bays specifically about “illegal substances.”
He did not articulate any safety-based justification linking drug questions to officer safety, such as concerns about weapons or violent conduct.

Under these circumstances, the Court explicitly holds that questions about drug possession and a request for consent to search were unrelated to the mission of the careless-driving stop. This comports with its prior observation that a dog sniff geared toward discovering drugs is unrelated to the traffic mission.

2. Did these unrelated actions prolong the stop?

The decisive question then became whether these unrelated questions and the consent request extended the time of the stop. The Court notes:

Middleton asked for consent as he ordered Bays out of the car for FSTs.
He then continued to diligently pursue the legitimate traffic investigation (conducting FSTs) after obtaining consent.
The K-9 arrived within about ten minutes of the initial stop, during a time frame consistent with the investigation into the traffic violation.

The Court characterizes the situation as one of “concurrent operations”: the officer was both:

Pursuing the mission of the traffic stop (investigating careless driving via FSTs, handling insurance issues), and
Simultaneously asking about drugs and obtaining consent to search.

The opinion analogizes this to an officer asking unrelated questions or requesting consent while awaiting the return of license or warrant checks from dispatch—something Kentucky has already tolerated under Carlisle and similar cases so long as no additional time is added.

Because there was no showing that the questioning or consent request added measurable time to the stop, the Court concludes that the unrelated drug inquiries did not unlawfully prolong the detention. No separate reasonable suspicion for a drug investigation was required.

3. Distinguishing Commonwealth v. Smith

The defense relied on Commonwealth v. Smith, 542 S.W.3d 276 (Ky. 2018), where a traffic stop was found unlawfully prolonged because the officer essentially abandoned investigating the traffic violation and embarked on a generalized drug investigation from the outset.

The Court distinguishes Smith on a crucial factual point:

In Smith, the officer never meaningfully pursued the traffic mission.
Here, Officer Middleton did focus on the traffic violation—ordering Bays out, attempting to obtain insurance proof, and conducting FSTs.
Because the traffic mission was actively and “diligently” pursued, the simultaneous drug questioning did not transform the stop into an impermissible general investigation.

F. Consent, the Dog Sniff, and Probable Cause

Having held that the stop was not unlawfully prolonged, the Court evaluates the later stages:

Bays’ consent to search the interior of the vehicle was obtained during a lawful detention and was not tainted by any constitutional violation.
A K-9 unit arrived within approximately ten minutes and performed a free-air sniff around the car’s exterior. Under U.S. Supreme Court precedent, such a sniff of the air outside a vehicle does not itself constitute a “search” in the Fourth Amendment sense.
When Goley exited the vehicle, officers saw her attempt to discard a small bag of suspected methamphetamine, adding to the evidence of drug activity.
The dog alerted on the driver’s side door, indicating the presence of narcotics.

Citing Meghoo v. Commonwealth, 245 S.W.3d 752 (Ky. 2008), the Court reiterates that a positive canine alert to a vehicle’s exterior provides probable cause to search the vehicle without a warrant. Here, the dog’s alert and Goley’s behavior together supplied robust probable cause, justifying a warrantless search of the trunk where the methamphetamine was found.

Bays did not contest that, if the dog sniff and observed conduct were lawful, they constituted probable cause for the trunk search; his arguments were directed at suppressing all results as fruits of an allegedly unlawful prolonged stop. With that theory rejected, the search of the trunk stands as valid.

G. The Role of the Confidential Informant Tip

The opinion carefully sidesteps issuing a definitive ruling on whether the CI tip alone created reasonable suspicion sufficient to justify a drug investigation or dog sniff. Because the Court held:

The stop was valid based on observed careless driving, and
The unrelated drug questions and consent did not prolong the stop,

it had no need to reach the question of independent reasonable suspicion based on the tip. That issue remains analytically open for future cases, at least as far as this memorandum opinion is concerned.

H. Other Doctrinal Threads

1. Unpublished status and RAP 40(D)

The Court prefaces its opinion with the standard notice that this decision is “NOT TO BE PUBLISHED,” citing RAP 40(D). Such decisions:

May not be cited or used as binding precedent in other Kentucky cases.
May be cited for consideration if no published opinion adequately addresses the issue, provided the full decision is supplied to the court and opposing parties.

Although not precedential, this opinion crystallizes how Kentucky will likely apply its “no de minimis extension” rule and “concurrent operations” doctrine to routine drug questioning and consent during traffic stops.

2. Abandoned arguments

The Court notes that Bays had argued below that the stop was unlawfully prolonged after the FSTs but abandoned that argument on appeal. Under Kentucky practice, issues not briefed on appeal are treated as abandoned, citing Halvorsen v. Commonwealth, 671 S.W.3d 68 (Ky. 2023).

IV. Complex Concepts Simplified

A. “Mission” of the Traffic Stop

The “mission” of a traffic stop is what the officer is legitimately supposed to be doing in response to the traffic violation. Examples include:

Verifying driver’s license and registration.
Checking for outstanding warrants.
Confirming insurance.
Issuing citations or warnings.
Investigating possible impaired driving (e.g., with FSTs) when warranted.

Actions outside this mission (like searching for drugs unrelated to signs of impairment) must either:

Be justified by separate reasonable suspicion or probable cause, or
Be done concurrently in a way that does not lengthen the stop at all.

B. Reasonable Suspicion vs. Probable Cause

Reasonable suspicion: A specific, articulable basis to suspect that criminal activity is afoot. It is more than a hunch but less than what is needed for an arrest. It can justify brief investigative detentions (like a Terry stop or a canine sniff that extends a traffic stop).
Probable cause: A fair probability, based on facts and circumstances, that a crime has been or is being committed or that contraband is present. Probable cause justifies arrests and certain warrantless searches, such as those of vehicles under the automobile exception.

In this case, the Court held that because the stop was not improperly extended, the officer did not need additional reasonable suspicion merely to ask about drugs or to request consent. Probable cause arose later from the dog’s alert and Goley’s actions.

C. Consent Searches

A consent search is a well-recognized exception to the warrant requirement. Key points:

The consent must be voluntary (no coercion, duress, or undue pressure).
The consenting party must have actual or apparent authority over the place or item searched.
If the consent follows an illegal detention, it may be invalid as “fruit of the poisonous tree.”

Here, the Court’s primary focus is on whether the detention was lawful when consent was obtained. Because it was, the consent stands, and all evidence that followed is admissible.

D. Dog (K-9) Sniffs and “Free Air Sniff”

A free air sniff is when a trained dog walks around the exterior of a vehicle to detect the odor of drugs emanating into open air. Under longstanding doctrine, such a sniff:

Is not itself a “search” under the Fourth Amendment.
Must not prolong a traffic stop unless supported by reasonable suspicion.
Can, if the dog alerts, provide probable cause to search the vehicle.

In Bays, the K-9 arrived quickly, and the sniff occurred during the ongoing, valid traffic investigation. The dog’s alert, combined with the passenger’s attempt to discard drugs, furnished probable cause.

E. Waiver vs. Forfeiture

Forfeiture is a failure to make a timely assertion of a right. Forfeited issues can sometimes be reviewed for palpable or plain error.
Waiver is the intentional relinquishment of a known right—often by affirmatively conceding an issue or stipulating to something. Waived issues usually cannot be revived on appeal at all.

Bays waived any argument that FSTs were outside the lawful mission of the traffic stop by expressly labeling them as part of “the only lawful purpose” below. On appeal he could not argue the opposite.

F. Palpable Error

Under Kentucky’s RCr 10.26, palpable error is a particularly serious, obvious error affecting substantial rights. To gain relief, a defendant must show:

The error is “plain” and readily noticeable.
It created a “probability of a different result” or was so fundamental as to threaten due process.

The Court’s opinion makes clear that ordinary conflicts in testimony or debatable interpretations of law do not automatically rise to this level.

V. Impact and Implications

A. For Law Enforcement

The decision, though unpublished, offers practical guidance:

Officers may ask about drugs and request consent to search even when the only objectively justified reason for the stop is a traffic violation, provided such questioning does not add time to the stop.
It remains critical to diligently pursue the traffic mission. If officers, like in Smith, ignore the violation and focus solely on a generalized drug investigation, the stop may be deemed unlawfully prolonged.
Careful articulation in reports and testimony of what tasks were performed, and when, can be outcome-determinative—especially regarding timelines of consent, FSTs, and K-9 deployment.

B. For Defense Counsel

From a defense perspective, this case underscores:

The danger of strategic concessions in suppression practice. A concession that some action was within the “lawful purpose” of the stop may later bar broader appellate challenges to that action.
The importance of preserving all plausible arguments regarding prolongation—both when the mission ended and whether intermediate steps (like FSTs) were justified.
The need to develop a precise timeline in suppression hearings (e.g., by securing body camera footage, dispatch logs, and careful cross-examination) to show that drug-inquiry activities added time to the stop.

C. For Trial Courts

The opinion reinforces:

The central role of trial judges as factfinders at suppression hearings—particularly in resolving conflicting testimony.
The importance of making explicit findings on key points (e.g., exactly when consent was given, how long various steps took, how diligently the traffic mission was pursued).
That appellate courts will defer to reasonable factual inferences, even when officer testimony is inconsistent, so long as substantial evidence supports the findings.

D. For Fourth Amendment Doctrine in Kentucky

On a doctrinal level, even as an unpublished memorandum, the case helps clarify Kentucky’s trajectory in traffic-stop law:

It confirms that drug-related questioning during a traffic stop is typically unrelated to the mission of enforcing traffic laws.
It simultaneously confirms that such unrelated inquiries are permissible without independent reasonable suspicion if they are pursued concurrently with mission-related tasks and do not prolong the stop.
It integrates Kentucky precedent (Davis, Turley, Carlisle, Clayborne, Smith) with U.S. Supreme Court doctrine (Rodriguez, Johnson, Muehler) into a coherent, if fact-sensitive, rule.

Future litigants, especially where no published Kentucky opinion is directly on point, may well cite this decision (under RAP 40(D) procedures) to argue about what counts as “prolongation” and how “concurrent operations” should be assessed in particular factual settings.

VI. Conclusion

Randall Bays v. Commonwealth of Kentucky is a nuanced memorandum opinion that, while not published or binding, provides a detailed and carefully reasoned application of modern Fourth Amendment principles to a common policing scenario: a traffic stop interwoven with suspicions of drug trafficking.

The Court affirms Bays’ conviction by:

Giving substantial deference to the trial court’s factual resolutions, including its characterization of “erratic” driving and its finding on the timing of consent.
Holding that defense concessions at the suppression stage can amount to a waiver that forecloses later appellate argument on those same issues.
Clarifying that asking about drugs and seeking consent to search are “unrelated” to a traffic stop’s mission but may lawfully occur during the stop if done concurrently with mission-related tasks and without prolonging the detention.
Reaffirming that a canine alert to a vehicle’s exterior, especially coupled with suspicious conduct by an occupant, provides probable cause to search the vehicle without a warrant.

In the broader landscape of Kentucky criminal procedure, this opinion underscores the vitality of the “no de minimis extension” rule and further develops the “concurrent operations” exception. It signals to both law enforcement and defense counsel that the fate of suppression motions will often turn on the meticulous reconstruction of timelines and the precision (or lack thereof) in trial-level concessions and factual findings.