Officers did not violate curtilage when they could see marijuana growing behind defendant’s mobile home. While the plants weren’t visible from the front of the curtilage, going to look for another door would have revealed it. It was also visible from the neighbor’s yard. State v. Hartrup, 511 S.W.3d 447 (Mo. App. Feb. 28, 2017):
Enclosures and obstacles demonstrate effective steps to create privacy—such as fenced areas, garages, and sheds. Here, the only proffered evidence of steps taken to protect sight of the marijuana from where the public accesses the home was its placement behind the home and a photograph showing a bush blocking the view of the side of the mobile home from the front door. A rational fact-finder could determine that the evidence sitting on a table behind a home, where visitors may find a second door and which was visible from the adjoining home, did not constitute effective steps to maintain a reasonable expectation of privacy.