The use of a drug dog at defendant’s apartment door violated the Fourth Amendment. Defendant’s garage across the road is a different matter, but it doesn’t have to be decided. Officers showed PC for a search of defendant’s garage in the affidavit for the search warrant independent of the dog sniff there. Jackson v. State, 2016 Tex. App. LEXIS 4774 (Tex.App. – Houston (14th Dist.) May 5, 2016).
Defendant’s warrantless blood draw was without exigent circumstances, and there is no Texas good faith exception. Perez v. State, 2016 Tex. App. LEXIS 4745 (Tex.App. – Houston (14th Dist.) May 5, 2016).*