D.Conn.: Once a protective sweep is over, officers have to leave or they separately violate the 4A by staying

Officers lacked a reasonable basis for believing that there was anyone else in the apartment to conduct a protective sweep. Staying too long after the protective sweep is a separate constitutional violation. “Accordingly, even if the protective sweep had been permissible under the circumstances, the officers exceeded their legal authority by remaining in the apartment beyond the time necessary to conduct a protective sweep. ‘Were this not the rule, searches begun as minor intrusions on domestic privacy would expand beyond their legitimate purposes.’ Oguns, 921 F.2d at 447. The officers’ continued presence after the conclusion of the protective sweep constituted another, distinct Fourth Amendment violation.” United States v. Butler, 2017 U.S. Dist. LEXIS 151710 (D. Conn. Sept. 19, 2017)