FL1: Knock-and-talk on motel room door didn’t need justification, but here it was because robbery getaway car was outside

Officers could conduct a knock-and-talk at a motel room door without reasonable suspicion based on the fact the getaway car from an armed robbery was in the parking lot. When the person opening the door was recognized as the robber from the store video, the officers had probable cause to enter on exigent circumstances and conduct a protective sweep. State v. McRae, 2016 Fla. App. LEXIS 9500 (1st DCA June 21, 2016).

Defendant’s pro se argument on appeal that officers violated 39 C.F.R. 233.2(c)(1) on U.S. Postal Mail Covers was raised for the first time on appeal, so it is reviewed for plain error. What there is in the record on this shows the CI knew which post office defendant was using. The error, if it is one, is anything but plain. State v. McGuirk, 2016 W. Va. LEXIS 537 (June 17, 2016).*