Defendant was seen leaving the premises when police showed up with a search warrant. Then they went after him and stopped him a distance a way to return him to the scene of the search. The stop lacked reasonable suspicion and violates Bailey, and defendant’s alleged consent was a mere submission to authority. State v. Nelson, 2017 La. App. LEXIS 109 (La.App. 2 Cir. Feb. 1, 2017).
The owner of a lost dog looked all over for his dog, finding a lookalike on a rescue website. He went to defendant’s place when he got no responses to email. There he saw dogs held in bad conditions and he reported them to the Humane Society which obtained a warrant. The initial entry was a private search. State v. Smith, 2017-Ohio-359, 2017 Ohio App. LEXIS 374 (9th Dist. Jan. 31, 2017).*