US v. Idrissa Bagayoko — 4th Cir. (Sep 17, 2026)
The U.S. Court of Appeals for the Fourth Circuit hears United States v. Idrissa Bagayoko. In 2021, after driving from New York to Maryland and selling two boxes of Sniper DDVP, Bagayoko was stopped in Elkton with eighteen more boxes holding 1,728 bottles of the unregistered pesticide, whose active ingredient is dichlorvos. A federal jury later convicted him of knowingly selling the pesticide and recklessly transporting hazardous material without the required shipping papers, and the district court ordered $5,640 in restitution. He says the officer unlawfully prolonged the traffic stop while waiting for backup before a dog sniff. Under Rodriguez, police may not extend a traffic stop for an unrelated investigation unless separate reasonable suspicion supports it. He also says each bottle, rather than each cardboard box, was the relevant package, so no single package reached the regulatory ten-pound threshold. Finally, he challenges restitution, arguing that the government was not a victim.
US v. Idrissa Bagayoko (No. 25-4230) — U.S. Court of Appeals for the Fourth Circuit, argued September 17, 2026.
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