OH2: Five officer knock-and-talk valid where defendant on porch when consent given

Five officers showed up at defendant’s house for a knock and talk and one went down the alley to check around back there. Defendant had a dog, and, when he came to the door, he was asked to come outside. Officers talked to him outside, and he agreed to a walk through but said he wanted to “call my people” on his cell phone, which the officers denied to let him do for safety reasons. The entry was still by consent. State v. Grigley, 2014-Ohio-3950, 2014 Ohio App. LEXIS 3883 (2d Dist. September 12, 2014).*

From a backpage.com ad, officers concluded that there was sex trafficking of a minor, and a cell phone was tracked [no saying of how] to a motel room. A woman had rented the room. A woman was seen leaving the room and she was met on the parking lot and she consented to an entry of the room. Defendant was in the room (with the minor in the shower), and he was arrested. A search warrant was obtained for the room after a plain view. The entry was by consent. United States v. McHenry, 2014 U.S. Dist. LEXIS 129445 (D. Minn. August 26, 2014).*

A known informant’s statement that defendant would show up at a Big Lots parking lot with cocaine in one of two described vehicles that defendant was known to drive was reasonable suspicion when he was seen there. State v. Skippings, 2014 N.M. App. LEXIS 92 (September 16, 2014).*