justification for the Fourth Amendment violation. Finally, the Court is not persuaded by the Commonwealth’s reliance on other appellate cases where detentions lasting longer than a few minutes were upheld. In each of those cases it was necessary rather then merely preferable, for ongoing investigation in order to “verify or dispel the suspicion.” Many of those cases involved the need to bring drug sniffing dogs to the scene of a seizure, where no other constitutionally permissible means of verifying the suspicion were reasonably available. See, e.g., Limonja v. Commonwealth, 8 Va. App. 532, 541-43, 383 S.E.2d 476 (1989) (citations omitted); United States v. Alpert, 816 F.2d 958 (4th Cir. 1987). But see United States v. Place, 462 U.S. 696, 77 L. Ed. 2d 110, 103 S. Ct. 2637 (1983) (<HOLDING>). The twenty-minute detention of the pick-up
holding that 20 minute detention under the circumstances of the ease was not arrest holding three to four hour detention of luggage unreasonable holding that a fiftynine minute detention to wait for a drug dog was reasonable where the officer requested the dog immediately after developing reasonable suspicion holding ninety minute detention of luggage awaiting arrival of trained narcotics dog unconstitutional holding that defendants consent to a search of their luggage was undermined by officers misrepresentation that a drug dog had alerted to their luggage