criteria.” Sharpe, 470 U.S. at 685, 105 S.Ct. 1568; see also Place, 462 U.S. at 709, 103 S.Ct. 2637 (“[I]n assessing the effect of the length of the detention, we take into account whether the police diligently pursue their investigation.”). Accordingly, the Place Court relied heavily upon the fact that the agents had advance notice of the defendant’s arrival, and thus “had ample time to arrange for their additional investigation ... and thereby could have minimized the intrusion on respondent’s Fourth Amendment interests,” but failed do so. Place, 462 U.S. at 709, 103 S.Ct. 2637. The Place Court further observed that the Fourth Amendment “violation was exacerbated seizure of luggage at airport was unreasonable under standards for investigative detentions); Sanders, 719 F.2d at 887 (<HOLDING>). As was the case in Place and in the cases
holding that defendants consent to a search of their luggage was undermined by officers misrepresentation that a drug dog had alerted to their luggage holding ninety minute detention of luggage awaiting arrival of trained narcotics dog unconstitutional holding a three and onehalf year delay was unreasonable holding seizure unreasonable due to length of detention of property holding three to four hour detention of luggage unreasonable