prolonged; and (4) the importance of the governmental interest alleged to justify the intrusion. Alpert, 816 F.2d at 964, citing United States v. Place, 462 U.S. 696, 708 n. 8, 103 S.Ct. 2637, 77 L.Ed.2d 110 (1983). DiGiovanni’s continued investigation after issuing the warning was entirely reasonable in light of these factors. First, any detention incident to that investigation was of limited duration. The encounter between Rodriguez and law enforcement personnel, from the moment he was pulled over until the currency’s discovery, lasted approximately forty minutes. Under these circumstances, even if Rodriguez’s detention occupied that entire time interval, it might not suggest a Terry Stop of unreasonable scope. See United States v. McFarley, 991 F.2d 1188, 1194 (4th Cir. 1993) (<HOLDING>). However, the alleged detention here only
holding that where officers had reasonable suspicion of a drug offense seizing defendants luggage for 38 minutes under terry did not mature into an unlawful arrest holding suspect for 20 minutes constituted an arrest holding that a defendants response to even an invalid arrest or terry stop may constitute independent grounds for arrest holding that a seizure was unlawful because certain facts had dispelled the officers reasonable suspicion holding that totality of circumstances supported reasonable suspicion that defendant was transporting drugs and therefore officer was justified in seizing truck