S.D.Ohio: Going onto the front porch to try a key in the lock didn’t violate Jardines; entering the already cracked open door did

Defendant had no reasonable expectation of privacy in the house searched. It was owned by others and where the electric bill was in another’s name. There was probable cause for a search of a second location. Police going on to the porch of a house to try a key was not unreasonable under Jardines because it was the front door. However, entry into the house required exigent circumstances, and it was lacking, so the search of the house is suppressed. United States v. Williams, 2015 U.S. Dist. LEXIS 81907 (S.D.Ohio June 24, 2015).

Defense counsel was not ineffective for not moving to suppress the search of a car that defendant didn’t own or have any interest in or was even in at the time of the search. State v. Abrams, 2015 Iowa App. LEXIS 538 (June 24, 2015).*

The pill bottle in defendant’s vehicle was in plain view, and that justified its search when defendant was removed from the vehicle because of his furtive movements and extreme jittery behavior indicative of drug use, coupled with the fact that the officer knew of defendant from a prior drug arrest. State v. Goddard, 2015 Iowa App. LEXIS 542 (June 24, 2015).*