N.D.Ill.: Use of defendant’s garage door opener to locate his apartment building was not an unreasonable search

Officers found four garage door openers in defendant’s vehicle that were lawfully seized. They used them on the address they thought belonged to defendant, 1717 South Prairie, in Chicago. They didn’t work. They drove around and one worked at “1819 South Michigan Avenue, a ten-story apartment and condominium building.” They used a key fob from the car to get into the lobby of the building, and then they were able to ascertain which unit was his. This was not an illegal search because it could have been done by asking the doorman. This is like United States v. Concepcion, 942 F.2d 1170 (7th Cir. 1991). Jardines provides no relief here because that case involved a single family dwelling and entering the curtilage. United States v. Correa, 2014 U.S. Dist. LEXIS 33084 (N.D. Ill. March 14, 2014), on reconsideration 2015 U.S. Dist. LEXIS 6978 (N.D. Ill. January 21, 2015) (posted here).

The state trooper’s suspicions about defendant’s temporary tag were not immediately dispelled after the stop, and it was reasonable then to continue the stop. United States v. Behrens, 551 Fed. Appx. 452 (10th Cir. 2014).*