GA: Where backdoor is the one always used, it doesn’t violate curtilage for officers to go to backdoor

Defendant’s backdoor was the common method of coming and going from his house, so the police did not violate curtilage by going to the back door. In defendant’s car in the driveway, however, was evidence from a burglary in plain view. There was probable cause to get a warrant for the car, and curtilage wasn’t violated. Cupe v. State, 2014 Ga. App. LEXIS 396 (June 19, 2014).

Under Texas law, ICE officer can make felony and misdemeanor arrests, and an off-duty ICE officer made a stop. “Facts known to Stone raised a potential for drug activity or criminal acts against children or law enforcement—felony offenses under Texas law—thus Stone, as a special investigator, had the powers of arrest, search, and seizure as to such felony offenses.” Guerra v. State, 2014 Tex. Crim. App. LEXIS 894 (June 18, 2014), aff’g Guerra v. State, 396 S.W.3d 233 (Tex. App.—Eastland 2013).*