AR: Def’s rear door shown as door where knock always answered, so curtilage not violated

Defendant’s house had a circle drive and a front door and a back door. The back door was found a normal place of entry. At the suppression hearing, the officer testified that he’d been there before on official business and knocked at the front door, got no answer, then went to the rear door where he would get an answer. Thus, the officers did not violate the curtilage. Jones v. State, 2014 Ark. App. 649, 2014 Ark. App. LEXIS 923 (November 12, 2014).

Unmeritorious arrest and search claim not pursued by counsel can’t form the basis of an IAC claim. Sherman v. State, 2014 Ark. 474 (November 13, 2014).*

Defendant was repeatedly told that he was not under arrest, and he was not seized when he signed the consent to search his car which was voluntary. Alternatively, the search of his car was justified by the automobile exception. United States v. Ibrahim, 2014 U.S. Dist. LEXIS 159517 (D. Minn. October 9, 2014), adopted 2014 U.S. Dist. LEXIS 159019 (D. Minn. November 12, 2014).*