CA4: Common hallway of apartment building not curtilage under Jardines

“[T]he common hallway of the apartment building, including the area in front of Makell’s door, was not within the curtilage of his apartment” under Jardines. United States v. Makell, 2018 U.S. App. LEXIS 12016 (4th Cir. May 8, 2018).

There was probable cause on the totality (without telling us what it was). United States v. Saunders, 2018 U.S. App. LEXIS 12015 (4th Cir. May 8, 2018)*;
People v. Brooks, 2018 NY Slip Op 03319, 2018 N.Y. App. Div. LEXIS 3267 (1st Dept. May 8, 2018) (likely informant hearsay).*

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