NC: Surrounding house for a knock-and-talk didn’t make the knock-and-talk unreasonable

Defendant had a running generator connected to his house and mold and condensation on the windows. A CI had said that defendant had a grow operation. Officers came to the house and confirmed the generator and windows from the front. They surrounded the house before the knock-and-talk, which was unusual, but not unreasonable or unconstitutional. They quickly and lawfully obtained enough to get a search warrant. State v. Kirkman, 2016 N.C. App. LEXIS 1321 (Dec. 20, 2016) [even though surrounding the house by definition is an invasion of the curtilage beyond the mere license to approach the front door?].

Defendant’s prior drug activity, a pending case, and a CI’s statement he’d transported drugs from Chicago to Waterloo was reasonable suspicion to continue the stop longer under Rodriguez. State v. Allen, 2016 Iowa App. LEXIS 1387 (Dec. 21, 2016).*

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