What is the current state of the law on "clear indication" in cases involving more suspicious circumstances than those in the past?

Facts involving more suspicious circumstances than those present here have not in the past met the clear indication standard. In United States v. Shields, 453 F.2d 1235 (9th Cir.) (per curiam), cert. denied, 406 U.S. 910, 92 S.Ct. 1615, 31 L.Ed.2d 821 (1972), for instance, the court stated that a clear indication would not exist where the suspect was highly nervous, standing rigidly, had fresh needlemarks on her arms, and had just made about an hour visit to Mexico. Id. at 1236. In United States v. Quintero-Castro, 705 F.2d 1099, 1100 (9th Cir.1983) (per curiam), the court held that the lower court could not properly find a clear indication where the defendant was nervous, paid cash, planned to stay at a hotel although he had relatives in the area, told conflicting stories, and was coming from a drug source country.