KS: SW for a house automatically includes authority to search the curtilage and thus a car in the driveway

A search warrant for a house automatically includes permission to search the curtilage and thus a car in the driveway even though it wasn’t specified in the search warrant. State v. Patterson, 49 Kan. App. 2d 1001, 319 P.3d 588 (2014).

Officers approached defendant because he appeared to be drinking from an open container in a car in a convenience store parking lot. When he unexpectedly reached to the floor, that was a furtive movement that justified a frisk of the car. State v. Shrewsbury, 2014-Ohio-716, 2014 Ohio App. LEXIS 692 (4th Dist. February 26, 2014).

Petitioner’s 2255 IAC on a search warrant claim states no facts other than defense counsel failed to file a motion to suppress. It shows nothing about whether the motion would even prevail if filed and how. Denied. Foster v. United States, 2014 U.S. Dist. LEXIS 24831 (W.D.N.C. February 26, 2014).*